Date: 18 December 2020 Our ref: 330546 West Suffolk Council Customer Services [email protected] Hornbeam House Crewe Business Park BY EMAIL ONLY Electra Way Crewe Cheshire CW1 6GJ T 0300 060 3900 Dear Sir / Madam Planning consultation: West Suffolk 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 Breckland 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. Page 2 of 14 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 Newmarket Heath 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