Date: 18 December 2020 Our ref: 330546

West Council Customer Services [email protected] Hornbeam House Crewe Business Park BY EMAIL ONLY Electra Way Crewe Cheshire CW1 6GJ

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Dear Sir / Madam

Planning consultation: Local Plan (Regulation 18) Issues and Options October 2020

Thank you for consulting Natural England on the above in your email of 12 October 2020.

Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.

Issues and Options Part 1 – Developing a Spatial Strategy

Vision The Councils’ vision seems appropriate and aligned with the three pillars of sustainable development. We believe that there should be a strategic approach to the protection and enhancement of the natural environment, including providing biodiversity net gain, and enhancing and improving connectivity of green infrastructure.

Strategic Objective SO14 Natural England advises that evidence is widely available to demonstrate that access to high quality open space close to where people live can significantly improve their physical and mental health and wellbeing. It is also important for meeting people’s recreational needs and their enjoyment of the countryside and its wildlife. We recommend that the policy wording includes “high-quality multi-use green spaces..”

Accessible open green space also reduces pressure on more sensitive designated sites of which there are a number within West Suffolk. Studies have shown that residential developments within a 7.5km radius have potential to cause increased visitor numbers to Special Protection Area (SPA), which can lead to recreational disturbance. Recreational pressures are also a threat to designated sites in the east of the district and in neighbouring Cambridgeshire, including Devil’s Dyke Special Area of Conservation (SAC).

We consider that there is a risk that developments may contribute to cumulative recreational impacts upon designated sites. Therefore it is also important to ensure that residential applications have sufficient green infrastructure to allow recreational activities on site and to ensure there is sufficient strategic green infrastructure in settlements to support residents. We would welcome that this is included as a policy or objective.

Our further advice on access, rights of way and green infrastructure are contained in Annex A.

Strategic Objective SO15 The 2020 Environment Bill introduces a mandatory requirement for biodiversity net gain in the

Page 1 of 14 planning system. Therefore Natural England advises that the wording of Strategic Objective SO15 is amended to remove the word “seek” from the sentence “…seek to achieve net biodiversity gain”. The Environment Bill also sets out that Local Nature Recovery Strategies will be the chief and mandatory mechanism for planning local delivery of Nature Recovery Networks (NRNs). We advise that your authority also considers proactively integrating NRNs within your strategic objectives.

Annex B includes more detailed advice to help the Council embed biodiversity net gain into relevant Local Plan policies.

Strategic issue 1 – climate change Natural England supports the Councils’ recognition of the climate emergency and the work being undertaken to achieve solutions, investments and actions to become carbon net-zero by 2030. We would welcome this date being included in the Local Plan as a commitment. We would also welcome a strategic objective to create an enhanced ecological network that is resilient to climate change.

Our further advice on climate change adaptation measures is in Annex A.

Strategic issue 3 – Economic growth and provision of strategic infrastructure Natural England would welcome the inclusion of enhancing and improving the connectivity of green infrastructure to this strategic issue.

Housing distribution options Natural England’s main message is that the natural assets of West Suffolk need to be protected, conserved and enhanced and that this should continue to be a key theme for the Local Plan as it evolves. To help achieve this, we believe that priority should be given to targeting growth in the most sustainable locations i.e. where impacts to the natural environment, through development and associated infrastructure, can be avoided and where maximum enhancements can be achieved by that development. Natural England may be able to provide detailed advice on this as site allocations are progressed, using the Stone Curlew Planning Tool to inform decisions. The Local Plan as it evolves should be underpinned by up to date environmental evidence.

Issues and Options Part Two – Local Issues

Climate change Natural England welcomes actions to reduce greenhouse gas emissions and adapt to climate change. The Local Plan should recognise the role of the natural environment to deliver measures to reduce the effects of climate change, for example tree planting to moderate heat island effects and for carbon offsetting. However planting of trees needs to be considered in the context of wider plans for nature recovery. Tree planting should only be carried out in appropriate locations, taking into consideration potential impacts on existing ecology and the opportunities to create alternative habitats that could deliver better enhancements for people and wildlife, and also store carbon effectively. Tree planting would not be appropriate in parts of Breckland SPA designated for Stone Curlew which require an open landscape.

Where woodland habitat creation is appropriate, consideration should be given to natural regeneration for the economic and ecological benefits this can achieve. Any tree planting should use native and local provenance tree species suitable for the location. Natural England advocates an approach which seeks to increase biodiversity and green infrastructure generally, not simply planting of trees, and protecting / enhancing soils, particularly peat soils.

The Local Plan should reflect the importance of remaining peat soils as a significant carbon store that can help to improve air quality and mitigate against climate change. The development strategy and relevant policies should seek to protect Best and Most Versatile Land, including peat soils, and contribute towards enhancement of degraded peat to deliver a wide range of environmental services including biodiversity, open space, flood risk and drainage benefits, in addition to helping to mitigate climate change.

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In addition, factors which may lead to exacerbate climate change (through more greenhouse gases) should be avoided (e.g. pollution, habitat fragmentation, loss of biodiversity) and the natural environment’s resilience to change should be protected. Green Infrastructure and resilient ecological networks play an important role in aiding climate change adaptation.

Natural Environment The Local Plan should set criteria based policies to ensure the protection of designated biodiversity and geological sites. Such policies should clearly distinguish between international, national and local sites1. Natural England advises that all relevant Special Areas of Conservation, Special Protection Areas, Ramsar sites2 and Sites of Special Scientific Interest (SSSIs) should be included on the proposals map for the area so they can be clearly identified in the context of proposed development allocations and policies for development. Designated sites should be protected and, where possible, enhanced.

The 2020 Environment Bill mandates the delivery of at least 10% measureable biodiversity net gain through all relevant development. Therefore in section 8.3 we would advise that a key sustainability issue is that “future development must maximise opportunities for biodiversity net gain”. We would also advise that the wording of section 8.7 is also amended to reflect this.

We agree that strategic buffers around Breckland SPA are retained but would welcome further research and up to date evidence to inform them, in particular the secondary Stone Curlew buffer. We also welcome the consideration of cumulative recreational impacts and suggest that approaches with neighbouring authorities are agreed.

We encourage a green infrastructure strategy that enhances the natural environment, supports the health and wellbeing of people, manages the effects of climate change and provides an alternative to sensitive designated sites.

Horseracing We welcome the statement that there is a great opportunity to work with the horseracing industry to improve the quality of the East Anglian Chalk National Character Area for the benefit of biodiversity. Newmarket racecourse is surrounded by part of SSSI, so the racecourse will play a pivotal role in ensuring the site remains in its current favourable condition. We would also welcome efforts to help restore the other unit of the SSSI (located north east of the town) to favourable condition.

Issues and Options Part Three – Settlements

Natural England is unable to put forward new sites for future development. Our advice is that the site assessment methodology should be based upon a robust and credible assessment of deliverability, the suitability of the land and surrounding environment to accommodate the proposed development, as well as the potential contribution towards sustainable development.

When assessing Site Allocations we would urge your authority to use Natural England’s Impact Risk Zones (IRZs), which are available for your authority to download or through magic.defra.gov.uk, to identify where development may have an impact on designated sites. We may be able to provide further advice through the use of the Stone Curlew Planning Tool as individual sites and housing numbers are considered. Impacts and mitigation requirements should be identified through the Sustainability Appraisal. The delivery of offsetting measures (including avoidance, mitigation, compensation and enhancement) will need to be secured through relevant Plan policies. Increased recreational pressure on international sites and SSSIs is likely to be a key issue which needs to be

1 International sites include: Special Protection Areas (SPAs); Special Areas of Conservation (SACs) and Ramsar sites1. National sites include Sites of Special Scientific Interest (SSSIs) and National Nature Reserves (NNRs) Local sites include wildlife Sites or geological sites (a variety of terms are in use for local sites).

2 Possible SACs, Potential SPAs, listed or proposed Ramsar sites and sites identified, or required, as compensatory measures for adverse effects on SACs and SPAs should be given the same level of protection as existing SACs and SPAs Page 3 of 14 addressed for some of the settlements identified. The scale of residential growth is significant hence the combined effects of proposed development will need to be considered where relevant.

In accordance with paragraph 171 of NPPF, the plan should allocate land with the least environmental or amenity value. Natural England expects sufficient evidence to be provided, through the SA and HRA, to justify the site selection process and to ensure sites of least environmental value are selected, e.g. land allocations should avoid designated sites and landscapes and significant areas of best and most versatile agricultural land and should consider the direct and indirect effects of development, including on land outside designated boundaries and within the setting of protected landscapes.

West Suffolk Council is part of the Natural England District Level Licensing (DLL) strategic approach to great crested newt (GCN) mitigation. We advise that Local Plan policies and site allocation assessments are informed by data available through DLL so that impacts of development on GCNs are minimised.

Risk zone mapping indicates the likely impact of development upon GCNs. This mapping can be used during Local Plan development to inform site allocation assessments to help guide development away from key GCN populations. Strategic Opportunity Area maps, which offer guidance for the delivery of new ponds, or the restoration of existing ponds, can be incorporated into Local Plan policies to help guide development away from potential GCN habitat.

Further guidance is available by contacting [email protected].

Natural England has previously been consulted on the Strategic Housing and Economic Land Availability Assessment (our ref 298069, dated 22 November 2019). However we would like to make the following updates to the settlement information presented in this report:

 Barningham – within IRZ of Weston Fen SSSI, part of Waveney and Little Ouse Valley Fens SAC

 Brandon – SSSI is also located south west of the town. This and Weeting Heath SSSI are part of Breckland SAC

 Bury St Edmunds – The Glen Chalk Caves, Bury St Edmunds SSSI and Horringer Court Caves SSSI are both located in the town. Both are notified for their bat populations. Parts of the town are within the 7.5km zone around Breckland SPA

 Exning – the settlement is within the Cambridgeshire SSSIs recreational pressure IRZ

 Fornham All Saints – there is no Special Area of Conservation close to the settlement.

 Newmarket – Devil’s Dyke is also designated as a SSSI and part is a Special Area of Conservation. Most of Newmarket is within the Cambridgeshire SSSIs recreational pressure IRZ

 The following settlements are also within the 7.5km zone of Breckland SPA – Barningham, Beck Row, Fornham All Saints, Fornham St Martin, Fornham St Genevieve, Great Barton, Hopton, Ingham and Worlington. Bardwell is not within this zone.

Habitats Regulations Assessment – Issues and Options version

Natural England is broadly satisfied that the Habitats Regulations Assessment Issues & Options version (Aecom, September 2020) has provided a robust assessment of the Regulation 18 stage of West Suffolk Councils draft Local Plan, in accordance with the requirements of the Conservation of Habitats and Species Regulations 2017 (as amended) and having regard to relevant case law. However we would like to make the following comments:

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2. Methodology Greater Cambridge Local Plan should also be considered for potential in-combination effects.

3. Pathways of impact Section 3.8 & 3.25 – We recommend updating the data used to determine the 1500m constraint zones of Stone Curlew nesting outside the SPA. Currently these zones are based on data only as recent as 2015. We would also welcome additional research into how far outside the SPA functionally linked land for Stone Curlew should extend (currently deemed to be 3km).

Section 3.13 & 3.14 – the document only refers to SSSI unit 4. For clarity, this unit is located outside of West Suffolk. The units of Breckland Forest SSSI located within West Suffolk (component units of Breckland SPA) are units 1 and 2.

Section 3.20 – we advise that in addition to the public rights of way network across Breckland SPA that much of Breckland Forest SSSI and parts of Breckland SAC are designated as access land.

4. Test of Likely Significance We note that air quality in Breckland SPA is to be taken forward to appropriate assessment but this contradicts with the scope in Section 1 where the air quality in the SPA was screened out. We advise that air quality should be taken to appropriate assessment for the SPA.

Devil’s Dyke SAC: Recreational pressure is an important threat to this site and so should be taken forward to appropriate assessment. Newmarket and its neighbouring settlements are located within the Cambridgeshire SSSIs recreational pressure IRZ to reflect potential zones of influence for publically accessible SSSIs sensitive to the effects of recreational pressure. This includes the Devil’s Dyke SAC and SSSI. The IRZ can be viewed on Magic.

Natural England believes that the issue requires a strategic approach to address the cumulative impacts of development, progressed via an evidence based approach through Local Plans. Central to this would be the identification of a package of offsetting measures focussing on the provision of Suitable Alternative Natural Greenspace (SANGS) capable of meeting people’s needs and diverting pressure away from, and thus avoiding adverse impact to, sensitive designated sites.

5. Conclusions and recommendations We welcome the policy recommendations but please note the above comments on updated research into the constraint buffer around Stone Curlews nesting outside of the SPA. Also an air quality policy should include Rex Graham and Devil’s Dyke SACs, in addition to Breckland SAC and SPA.

Appendix B. SHELAA site screening for LSE Although time constraints mean we have not checked every site for their potential Likely Significant Effects, we note that sites in Great Barton are within 7.5km of Nightjar / Woodlark habitat of Breckland SPA.

Additional advice on air quality Natural England is currently reviewing how we provide air quality advice on likely impacts. This could mean in future that thresholds and criteria will be changed based on evidence and recent case law.

We would also advise the Council, as the Competent Authority, to seek its own legal advice on the implications of the ruling made by the Court of Justice of the European Union (the CJEU) on the interpretation of the Habitats Directive in the case of Coöperatie Mobilisation (also known as the Dutch Nitrogen Case) (Joined Cases C-293/17 and C-294/17).

Additional advice on Breckland SPA We would advise you as the competent authority that this plan will need consideration in line with the legal advice you have commissioned.

It is Natural England’s role, as a statutory nature conservation adviser, to provide advice about the ecological impacts of any development proposals on nationally and internationally designated sites.

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In our responses regarding ecological impacts in the Breckland area we refer to any actions taken to address these impacts using the phrase ‘offsetting measures’. This term encapsulates everything from measures to avoid impact, enhancement measures, ‘mitigation’ or ‘compensation’ measures in accordance with the Conservation of Habitats and Species Regulations 2017. Whilst Natural England may offer comment on the appropriateness of these measures, or their likely ecological success it is for the Local Authority, in their capacity as the competent authority, to determine the legal status of these measures. We will continue to work with yourselves and adjacent authorities to explore a pragmatic way forward which ensures the protection of the special habitats and species in your LPA area.

Interim Sustainability Appraisal Report

We welcome the framework of the Sustainability Appraisal (SA) as presented in section 3.3. However we advise that the framework for Communities Overall includes reference to improving people’s access to nature in addition to green infrastructure.

We also welcome the objective to achieve biodiversity net gain. We advise this should be tested as the plan develops. It can be considered alongside other economic, social and environmental objectives, for example highlighting areas where there is a lack of open space provision or issues of health and wellbeing and linking to how biodiversity net gain may help to tackle these issues as part of wider green infrastructure.

Site options appraisal SAC – We would recommend that it is noted that SHELAA sites within Newmarket and Exning are close to the Devil’s Dyke SAC which is at risk from recreational pressures.

SSSI – we would advise that where a SSSI is a component part of either a SAC or SPA that the SSSI is categorised on the same red-amber-green scale as its parent SAC or SPA.

Natural England is unable to provide any detailed comments on the preliminary findings of the SA. We will be pleased to provide further comment as the detailed SA emerges, through preparation of the Local Plan and evidence documents. The evidence should be used to guide the most sustainable locations for development, prioritising avoidance of impacts to the natural environment including recreational pressure, air quality and water. We would also expect this to identify opportunities for development to implement significant enhancements to the ecological network. The delivery of enhancements should be secured through the relevant allocation and biodiversity policies.

Sustainable Settlements Study Natural England advises that high quality open space includes alternative natural greenspace which is an important tool in mitigating the effects on recreational pressure associated with new housing development on more sensitive designated sites. Whilst formal opportunities such as play parks and recreation grounds are an important component of open space, more informal areas are also of importance for education, exercise and recreation, as well as for wildlife. Natural England’s guidance on Accessible Natural Greenspace Guidance is detailed in Nature Nearby.

Other advice Further advice on what we would expect to be included within Plan policies, including the biodiversity policy, is provided in Annex A.

Annex B includes more detailed advice to help the Council embed biodiversity net gain into the relevant Local Plan policies.

We hope our comments are helpful. For any queries relating to the specific advice in this letter only please contact Richard Hack on 020 8720 3721. For any new consultations, or to provide further

Page 6 of 14 information on this consultation please send your correspondences to [email protected].

Natural England would be happy to provide additional advice through our Discretionary Advice Service.

We look forward to being consulted at the next stage of the Local Plan review.

Yours faithfully

Richard Hack

Richard Hack Norfolk & Suffolk Team

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Annex A – Further advice on Local Plan Policies

Access & rights of way Natural England advises that the Plan should include policies to ensure protection and enhancement of public rights of way and National Trails, as outlined in paragraph 98 of the NPPF. Recognition should be given to the value of rights of way and access to the natural environment in relation to health and wellbeing and links to the wider green infrastructure network. The plan should seek to link existing rights of way where possible, and provides for new access opportunities and avoid building on open space of public value as outlined in paragraph 97 of the NPPF.

Air pollution We would expect the plan to address the impacts of air quality on the natural environment. In particular, it should address the traffic impacts associated with new development, particularly where this impacts on international sites and SSSIs. The environmental assessment of the plan (SA and HRA) should also consider any detrimental impacts on the natural environment, and suggest appropriate avoidance or mitigation measures where applicable.

Natural England advises that one of the main issues which should be considered in the plan and the SA/HRA are proposals which are likely to generate additional nitrogen emissions as a result of increased traffic generation, which can be damaging to the natural environment.

The effects of local roads in the vicinity of any proposed development on nearby designated nature conservation sites (including increased traffic, construction of new roads, and upgrading of existing roads), and the impacts on vulnerable sites from air quality effects on the wider road network in the area (a greater distance away from the development) can be assessed using traffic projections and the 200m distance criterion followed by local Air Quality modelling where required. We consider that the designated sites at risk from local impacts are those within 200m of a road with increased traffic3, which feature habitats that are vulnerable to nitrogen deposition/acidification. APIS provides a searchable database and information on pollutants and their impacts on habitats and species.

Biodiversity and Geodiversity The Plan should set out a strategic approach, planning positively for the creation, protection, enhancement and management of networks of biodiversity. There should be consideration of geodiversity conservation in terms of any geological sites and features in the wider environment.

A strategic approach for networks of biodiversity should support a similar approach for green infrastructure (outlined below). Planning policies and decisions should contribute and enhance the natural and local environment, as outlined in para 170 of the NPPF. Plans should set out the approach to delivering net gains for biodiversity. Net gain for biodiversity should be considered for all aspects of the plan and development types, including transport proposals, housing and community infrastructure.

Climate change adaptation Climate change is complex and fast moving. Natural England has recently published the second edition of its Climate Change Adaptation Manual which addresses the gap between the general principles of climate change and how adaptation to climate change may work. To note, there are specific sections on Green Infrastructure and Access & Recreation.

Nature-based Solutions (NbS) can contribute to reducing net greenhouse gas emissions as achieving this is a statutory requirement for the UK and England. This will require major changes in the way we manage the natural environment, alongside changes in energy, transport and other sectors. NbS is an increasingly prominent concept to describe actions that address societal challenges, such as climate change, in ways that benefit both people and biodiversity. Woodland creation and peatland restoration

3 The ecological effects of diffuse air pollution (2004) English Nature Research Report 580 Design Manual for Roads and Bridges Volume 11, Section 3 Part 1 (2007), Highways Agency

Page 8 of 14 offer the largest potential contributions to net-zero. New woodland takes up carbon from the atmosphere via photosynthesis, and peatland restoration stops greenhouse gas emissions from the oxidation of degraded peat. Note however that not all environmental management for net-zero is true NbS and not all NbS deliver climate change mitigation.

The Reducing UK Emissions: 2020 Progress Report to Parliament includes new advice to the UK Government on securing a green and resilient recovery following the COVID-19 pandemic. It recommends that Ministers seize the opportunity to turn the COVID-19 crisis into a defining moment in the fight against climate change. Its report highlights key investment priorities such as tree planting, green infrastructure and infrastructure to make it easy for people to walk, cycle and work remotely.

Designated sites The Local Plan should be screened under Regulation 105 of the Conservation of Habitats and Species Regulations 2017 (as amended) at an early stage so that outcomes of the assessment can inform key decision making on strategic options and development sites. It may be necessary to outline avoidance and/or mitigation measures at the plan level, which will usually need to be considered as part of an Appropriate Assessment, including a clear direction for project level HRA work to ensure no adverse effect on the integrity of internationally designated sites. It may also be necessary for plans to provide policies for strategic or cross boundary approaches, particularly in areas where designated sites cover more than one Local Planning Authority boundary.

Flood and Water Management Natural England expects the Local Plan to consider the strategic impacts on water quality and resources as outlined in paragraph 170 of the NPPF. We would also expect the plan to address flood risk management in line with the paragraphs 155-165 of the NPPF.

The Local Plan should be based on an up to date evidence base on the water environment and as such the relevant River Basin Management Plans should inform the development proposed in the Local Plan. These Plans outline the main issues for the water environment and the actions needed to tackle them. Local Planning Authorities must in exercising their functions, have regard to these plans.

The Local Plan should contain policies which protect habitats from water related impacts and where appropriate seek enhancement. Priority for enhancements should be focussed on international sites, SSSIs and local sites which contribute to a wider ecological network.

Plans should positively contribute to reducing flood risk by working with natural processes and where possible use Green Infrastructure policies and the provision of Sustainable Drainage Systems (SuDS) to achieve this.

Green Infrastructure Green infrastructure refers to the living network of green spaces, water and other environmental features in both urban and rural areas. It is often used in an urban context to provide multiple benefits including space for recreation, access to nature, flood storage and urban cooling to support climate change mitigation, food production, wildlife habitats and health and well-being improvements provided by trees, rights of way, parks, gardens, road verges, allotments, cemeteries, woodlands, rivers and wetlands.

Green infrastructure is also relevant in a rural context, where it might additionally refer to the use of farmland, woodland, wetlands or other natural features to provide services such as flood protection, carbon storage or water purification.

A strategic approach for green infrastructure is required to ensure its protection and enhancement, as outlined in para 171 of the NPPF. Green Infrastructure should be incorporated into the plan as a strategic policy area, supported by appropriate detailed policies and proposals to ensure effective provision and delivery. Evidence of a strategic approach can be underpinned by green infrastructure strategy. We encourage the provision of green infrastructure to be included as a specific policy in the

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Local Plan or alternatively integrated into relevant other policies, for example biodiversity, green space, flood risk, climate change, reflecting the multifunctional benefits of green infrastructure.

We advise the Council to prepare a map of the existing ecological network and opportunities for enhancement. An accompanying strategy should identify opportunities for delivery of biodiversity and green infrastructure enhancement projects through the Plan’s major development and biodiversity and green infrastructure policies. The policy should make provision for appropriate quantity and quality of green space to meet identified local needs as outlined in paragraph 96 of the NPPF. Provision of sufficient quantity of high quality alternative natural greenspace is an important tool in mitigating the effects on recreational pressure associated with new housing development on more sensitive designated sites. Natural England’s guidance on Accessible Natural Greenspace Guidance is detailed in Nature Nearby.

Landscape Natural England expects the Plan to include strategic policies to protect and enhance valued landscapes, as well criteria based policies to guide development.

Priority habitats, ecological networks and priority and/or legally protected species populations The Local Plan should be underpinned by up to date environmental evidence. This should include an assessment of existing and potential components of local ecological networks. This assessment should inform the Sustainability Appraisal, ensure that land of least environment value is chosen for development, and that the mitigation hierarchy is followed and inform opportunities for enhancement as well as development requirements for particular sites.

Priority habitats and species are those listed under Section 41 of the Natural Environment and Rural Communities Act, 2006 and UK Biodiversity Action Plan (UK BAP). Further information is available here: Habitats and species of principal importance in England. Local Biodiversity Action Plans (LBAPs) identify the local action needed to deliver UK targets for habitats and species. They also identify targets for other habitats and species of local importance and can provide a useful blueprint for biodiversity enhancement in any particular area.

Protected species are those species protected by law. Further information can be found in our standing advice for protected species. Sites containing watercourses, old buildings, significant hedgerows and substantial trees are possible habitats for protected species.

Ecological networks are coherent systems of natural habitats organised across whole landscapes so as to maintain ecological functions. A key principle is to maintain connectivity – to enable free movement and dispersal of wildlife e.g. badger routes, river corridors for the migration of fish and staging posts for migratory birds. Local ecological networks will form a key part of the wider Nature Recovery Network as set out in the Environment Bill 2020. Where development is proposed, opportunities should be explored to contribute to the enhancement of ecological networks.

Planning positively for ecological networks will also contribute towards a strategic approach for the creation, protection, enhancement and management of green infrastructure, as identified in paragraph 171 of the NPPF.

Where a plan area contains irreplaceable habitats, such as ancient woodland, ancient and veteran trees, there should be appropriate policies to ensure their protection. Natural England and the Forestry Commission have produced standing advice on ancient woodland, ancient and veteran trees.

Soils and agricultural land The Local Plan should give appropriate weight to the roles performed by the area’s soils. These should be valued as a finite multi-functional resource which underpins our wellbeing and prosperity. Decisions about development should take full account of the impact on soils, their intrinsic character and the sustainability of the many ecosystem services they deliver.

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The plan should safeguard the long term capability of best and most versatile agricultural land (Grades 1, 2 and 3a in the Agricultural Land Classification) as a resource for the future in line with NPPF paragraph 170.

Tranquillity The Local Plan should identify relevant areas of tranquillity and provide appropriate policy protection to such areas as identified in paragraphs 100 and 180 of the NPPF. The CPRE have mapped areas of tranquillity which are a helpful source of evidence for the Local Plan and SA.

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Annex B – Additional advice on Biodiversity Net Gain

General advice and benefits of embedding biodiversity net gain Biodiversity net gain is a key tool to help nature’s recovery and is also fundamental to health and wellbeing as well as creating attractive and sustainable places to live and work in. The National Planning Policy Framework (NPPF) highlights the role of “policies and decision making to minimise impacts and provide net gains for biodiversity” (para 170).

Planning Practice Guidance describes net gain as an “approach to development that leaves the natural environment in a measurably better state than it was beforehand” and applies to both biodiversity net gain and wider environmental net gains. For biodiversity net gain the Biodiversity Metric 2.0 can be used to measure gains and losses to biodiversity resulting from development. We advise you to use this metric to implement development plan policies on biodiversity net gain. Any action, as a result of development, that creates or enhances habitat features can be measured using the metric and a result count towards biodiversity net gain.

The Chartered Institute of Ecology and Environmental Management (CIEEM), along with partners, has developed good practice principles for biodiversity net gain, which can assist plan-making authorities in gathering evidence and developing policy.

The 2020 Environment Bill mandates the delivery of at least 10% measureable biodiversity net gain through all relevant development. It is expected to become an Act of Parliament before this Local Plan is adopted.

Advice on wider environmental gains Natural England focusses our advice on embedding biodiversity net gain in development plans, since the approach is better developed than for wider environmental gains. However your authority should consider the requirements of the NPPF (paragraph 72, 102, 118 and 170) and maximise opportunities for wider environmental net gain wherever possible. This can be achieved by considering how policies and proposed allocations can contribute wider environmental enhancement, help adapt to the impacts of climate change and/or take forward elements of existing green infrastructure, open space or biodiversity strategies. Opportunities for environmental gains, including Nature-based Solutions (NbS) to help adapt to climate change, might include:

 Identifying opportunities for new multi-functional green and blue infrastructure  Managing existing and new public spaces to be more wildlife friendly (e.g. by sowing wild flower strips) and climate resilient  Planting native trees, including street trees, characteristic to the local area to make a positive contribution to the local landscape  Improving access and links to existing greenspace, identifying improvements to the existing public rights of way network or extending the network to create missing footpath or cycleway links  Restoring neglected environmental features (e.g. a hedgerow or stone wall or clearing away an eyesore)  Designing a scheme to encourage wildlife, for example by ensuring lighting does not pollute areas of open space or existing habitats

Any habitat creation and/or enhancement as a result of the above may also deliver a measurable biodiversity net gain.

Evidence gathering Existing environmental evidence can be gathered from various sources including online data sources like Magic, Local Environmental Record Centres and strategies for green infrastructure, open space provision, landscape character, climate and ecosystem services and biodiversity opportunity mapping. Biodiversity data can also be obtained from developments that were subject to Environmental Impact Assessment (EIA) monitoring, the discharge of conditions or monitoring information from legal Page 12 of 14 agreements with a biodiversity element. This can help establish a baseline to understand what assets exist and how they may relate to wider objectives in the plan area. Cross boundary environmental opportunities can also be considered by working with neighbouring authorities, local nature partnerships and/or the local enterprise partnership. The relationship between environmental assets and key strategic growth areas may help to highlight potential opportunities that development could bring for the natural environment. The following may also be useful when considering biodiversity priorities in your plan area:

 What biodiversity currently exists, what is vulnerable or declining?  How are existing assets connected, are there opportunities to fill gaps and improve connectivity?  How does the above relate to neighbouring authority areas, can you work collaboratively to improve links between assets or take strategic approaches to address issues or opportunities?

Applying the mitigation hierarchy The plan’s approach to biodiversity net gain should be compliant with the mitigation hierarchy, as outlined in paragraph 175 of the NPPF. The policy should ensure that biodiversity net gain is not applied to irreplaceable habitats and should also make clear that any mitigation and/or compensation requirements for international sites should be dealt with separately from biodiversity net gain provision.

Policies and decisions should first consider options to avoid adverse impacts on biodiversity from occurring. When avoidance is not possible impacts should be mitigated and finally, if there is no alternative, compensation provided for any remaining impacts. Biodiversity net gain should be additional to any habitat creation required to mitigate or compensate for impacts. It is also important to note that net gains can be delivered even if there are no losses through development.

The policy for net gain, or its supporting text, should highlight how losses and gains will be measured. The Biodiversity Metric 2.0 can be used for this purpose as a fully tested metric that will ensure consistency across the plan-area and we would encourage its use. Alternatively your authority may choose to develop a bespoke metric, provided this is evidenced based. The following may also be useful considerations in developing plan policies:

 Use of a map within the plan. Mapping biodiversity assets and opportunity areas ensures compliance with national planning policy and also helps to clearly demonstrate the relationship between development sites and opportunities for biodiversity net gain.  Use of a biodiversity net gain target. Any target should be achievable and evidence based and may be best placed in lower tier documents or a Supplementary Planning Document, to allow for regular updates in line with policy and legislation.  Consideration should be given to thresholds for different development types, locations or scales of development proposals and the justification for this. Setting out the scope and scale of expected biodiversity net gains within Infrastructure Delivery Plans can help net gain to be factored into viability appraisals and land values. Natural England considers that all development, even small scale proposals, can make a contribution to biodiversity. Your authority may wish to refer to Technical Note 2 of the CIEEM good practice principles which provides useful advice on how to incorporate biodiversity net gain into small scale developments.  Policy should set out how biodiversity net gain will be delivered and managed and the priorities for habitat creation or enhancement in different parts of the plan area. The plan policy should set out the approach to on-site and off-site delivery. Natural England advises that on-site provision should be preferred as it helps to provide gains close to where a loss may have taken place. Off- site contributions may, however, be required due to limitations on-site or where this best meets wider biodiversity objectives set in the development plan. Further detail could be set out in a supplementary planning document.  The policy could also usefully link to any complementary strategies or objectives in the plan, such as green infrastructure.

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Site allocation appraisal During the site appraisal stage and before selecting which sites to take forward as allocations in the plan, the following may be useful to ensure opportunities for biodiversity net gain are secured:

 Does the site present significant risks to biodiversity? If so, have alternative sites with lesser impacts been explored?  What site specific recommendations can help delivery biodiversity net gain, for example what further survey work may be required at the planning application stage?  Whether the site can accommodate on-site biodiversity net gain provision or whether there is a need for off-site contributions? What types of habitat creation or enhancement are most appropriate?  Do there need to be any restrictions on the type of development that will be acceptable or particular parts of the site that should be not be developed?

During the site selection process, potential sites should be judged in accordance with all policies in the NPPF, including selecting land with the least environmental value, where consistent with other policies. The Biodiversity Metric can be useful during this process to understand the opportunities on a site, test indicative biodiversity net gains and to ensure sites of high biodiversity value are not selected.

Natural England encourages developers, promoting sites for inclusion in the Plan, to use its Discretionary Advice Service to discuss opportunities for biodiversity net gains on individual sites. This helps to ensure evidence is provided and appropriate ways to deliver biodiversity net gain can be included in site allocations if they progress. This can also help speed up the planning application stage.

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