B&MSDC Supplementary Planning Documents Consultation
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B&MSDC Supplementary Planning Documents Consultation
Draft Biodiversity and Trees SPD Consultation Document - May 2024
Representation ID: 23608
Received: 26/06/2024
Respondent: Sproughton Parish Council
Comments
1.2: Maintaining genetic diversity needs to be built into the planning system. Each planning application should consider if the application will impact genetic diversity of the area e.g. wildlife corridors must be retained or diverted but not cut-off by the development.
1.4-1.6: All good thoughts however it would be worth explaining exactly how the planning process will be updated to ensure this happens.
2.5: Suggest adding ‘Green Spaces’ – ‘along with green spaces, footpaths, allotments…..’
2.6/2.8.4: The initial benchmark that should be used when assessing an application should be based on an evaluation of the biodiversity mix prior to any preparation of a site for development. Which should include an assessment of the biodiversity that moves across the site using it as a wildlife corridor.
3.2(1): This is a good aim but why is the Salt Storage site @ Sproughton Enterprise Park being allowed to transfer its biodiversity responsibilities to remote projects when there are efforts going on just yards from their site to create wildlife areas and save biodiversity. Transference of biodiversity to a far-flung site should be last resort. Utilising nearby sites should be the preference and first choice.
3.2.(2): Mitigation should not be payments for wildlife improvements in other areas, BDC should be pushing for local mitigation by designating more green spaces locally to improve the local biodiversity and local environment for residents so they don’t need to go out of district to access green spaces. There appears to be a policy to allow depletion of local green residential infrastructure, degrading the quality of life for local residents and habitat, and then mitigating for this by improving the quality of habitats and residential areas in other districts. The objective should be to improve biodiversity in all areas especially where development is planned.
3.2.(3): The meaning of this is unclear? How do you judge what are Protected Habitat sites. Planners are very good at arguing that nothing is ‘protected’ unless they want it to be. Only European designated habitat sites have any clout here and then there is always the ‘planning balance’ which seems to be whatever balance that achieves whatever they want. This is too vague and open to interpretation which will be used by developers to argue their case. Replace ‘integrity’ with ‘the Protected Habitats Site’.
3.4: The Sproughton Nature Reserve should be added to this document. The legal agreement is being worked on at the moment it can be marked as ‘formal designation in progress’.
3.6.7: This must be completed before any work is done on preparing an area for development to obtain a true record of the levels of biodiversity and potential impact. Otherwise, any work done may have an adverse impact and hence the survey is not a true representation.
3.6.11: Using SANGS as mitigation improves the local residential and Biodiversity environment. Why is there a priority on improving other areas and not the immediate area.
Section 4:
The hierarchy places SANGS which come under avoidance and mitigation above compensation and yet for the Orwell RAMSAR sites payment by Tariffs are the default with SANGS a possibility to supplement Tariff payments? Why the inconsistency?
BNG calculations are set out. The hierarchy for BNG recommends on-site BNG. If off-site it recommends BNG should be delivered as close to the site is possible and the last option is off-site in a neighbouring area.
Biodiversity Net Gain Sites can be registered for about £700 but it’s a 30 year contract. Sproughton has two local sites – Land West of Church Lane & the proposed LNR - Chantry Cut Island which if registered could attract payments towards the management of the site for biodiversity improvements but they would have to remain Biodiversity Gain Sites for 30 years. BMSDC should commit to helping local groups/Parish Council’s create their own such sites then at least off-site mitigation will remain in the area.
4.29: Is there are up to date list of all sites within the district that are potential BNG. There are several within Sproughton parish that should be included.
4.32: Green borders should be included in this list, i.e. Hedgerows instead of Fences and walls.
Section 5:
5.1.1: Why not 15% if delivered on site and 25% if delivered elsewhere as mitigation to encourage green spaces in new development. This will appeal to developers as it will cost them less. Destroying existing biodiversity habitat and creating alternative habitat is disruptive and damaging to wildlife therefore the need for mitigation etc needs to be far greater than what is removed to ensure the eventual outcome is an improvement. If one acre of woodland is destroyed in one place the wildlife and all the associated biodiversity does not get on a bus to be transferred to a newly planted site elsewhere. There is going to be loss so the net gain planned needs to be greater to accommodate that loss and movement of as much biodiversity as possible needs to be managed and nurtured to re-establish as much as possible.
5.3.1: One issue is that the ecology reports required to identify the necessary species surveys normally have no local engagement – the local parish councils should be contacted to provide inormation. The desktop surveys looking for records are completely inadequate because the system of reporting is completely unknown to most people so virtually nothing actually gets reported. This is a flawed approach.
Any on site ecology survey is done by an expert but it is a brief site visit – a survey over several days would be more comprehensive. Typically, the ecology report for Chantry Vale / Wolsey Grange gave some information about potential birds but said there was no evidence of raptors when at that time just about every local knew that Kestrals were hunting for their chicks every day, in fact every minute of every day, in Chantry Vale. The Ecologist should be required to check with local Parishes or nature groups, because some species may not be present when the ecologist surveys the site, Some may be seasonal at a completely different time of year, some may be Transitory but regular visitors of a site that is important to their normal movements and some may just not be so obvious as to be picked up in a one day visit to a large diverse habitat site.
5.4.1: As above, the SBIS database is not particularly useful. For example the Taylor Wimpey (Wolsey Grange, Sproughton) ecologist used this over a period of 25 years for the WG site and the total number of reports submitted by the public amounted to less than a councillor saw as roadkill on the A1071 the week the ecologists report was published! It may identify a possibility to look for but the lack of any SBIS report about any biodiversity most certainly doesn’t exclude its presence. It just means no one has reported it. What is more the standard of report / verification / identification required is almost professional so even if a local resident were to see something really rare like a Pine Martin it probably wouldn’t make the report as an inaccurate / doubtful record. The principle of SBIS is good but in practice it is less useful due to minimal coverage. Local residents and Parish Councils have a far more detailed knowledge of their surroundings and are always overlooked until the surveys (which may be looking for the wrong biodiversity in the wrong place) have been completed. Early contact with parish councils is important their feedback should be included.
5.5.5: We agree with this although, there will be probably be quite a lot of debate over a parish councils view of a site, compared to some modelling by an ecologist claiming something else.
5.7: Although the scheme sounds reasonable the final conclusion essentially says building wherever wanted provided biodiversity is moved to a new site.
5.9.1 We are pleased that Babergh has included this point given the lack of action over the ripping out of the ancient hedgerow at Wolsey Grange, Sproughton.
Comments
1.2: Maintaining genetic diversity needs to be built into the planning system. Each planning application should consider if the application will impact genetic diversity of the area e.g. wildlife corridors must be retained or diverted but not cut-off by the development.
1.4-1.6: All good thoughts however it would be worth explaining exactly how the planning process will be updated to ensure this happens.
2.5: Suggest adding ‘Green Spaces’ – ‘along with green spaces, footpaths, allotments…..’
2.6/2.8.4: The initial benchmark that should be used when assessing an application should be based on an evaluation of the biodiversity mix prior to any preparation of a site for development. Which should include an assessment of the biodiversity that moves across the site using it as a wildlife corridor.
3.2(1): This is a good aim but why is the Salt Storage site @ Sproughton Enterprise Park being allowed to transfer its biodiversity responsibilities to remote projects when there are efforts going on just yards from their site to create wildlife areas and save biodiversity. Transference of biodiversity to a far-flung site should be last resort. Utilising nearby sites should be the preference and first choice.
3.2.(2): Mitigation should not be payments for wildlife improvements in other areas, BDC should be pushing for local mitigation by designating more green spaces locally to improve the local biodiversity and local environment for residents so they don’t need to go out of district to access green spaces. There appears to be a policy to allow depletion of local green residential infrastructure, degrading the quality of life for local residents and habitat, and then mitigating for this by improving the quality of habitats and residential areas in other districts. The objective should be to improve biodiversity in all areas especially where development is planned.
3.2.(3): The meaning of this is unclear? How do you judge what are Protected Habitat sites. Planners are very good at arguing that nothing is ‘protected’ unless they want it to be. Only European designated habitat sites have any clout here and then there is always the ‘planning balance’ which seems to be whatever balance that achieves whatever they want. This is too vague and open to interpretation which will be used by developers to argue their case. Replace ‘integrity’ with ‘the Protected Habitats Site’.
3.4: The Sproughton Nature Reserve should be added to this document. The legal agreement is being worked on at the moment it can be marked as ‘formal designation in progress’.
3.6.7: This must be completed before any work is done on preparing an area for development to obtain a true record of the levels of biodiversity and potential impact. Otherwise, any work done may have an adverse impact and hence the survey is not a true representation.
3.6.11: Using SANGS as mitigation improves the local residential and Biodiversity environment. Why is there a priority on improving other areas and not the immediate area.
Section 4:
The hierarchy places SANGS which come under avoidance and mitigation above compensation and yet for the Orwell RAMSAR sites payment by Tariffs are the default with SANGS a possibility to supplement Tariff payments? Why the inconsistency?
BNG calculations are set out. The hierarchy for BNG recommends on-site BNG. If off-site it recommends BNG should be delivered as close to the site is possible and the last option is off-site in a neighbouring area.
Biodiversity Net Gain Sites can be registered for about £700 but it’s a 30 year contract. Sproughton has two local sites – Land West of Church Lane & the proposed LNR - Chantry Cut Island which if registered could attract payments towards the management of the site for biodiversity improvements but they would have to remain Biodiversity Gain Sites for 30 years. BMSDC should commit to helping local groups/Parish Council’s create their own such sites then at least off-site mitigation will remain in the area.
4.29: Is there are up to date list of all sites within the district that are potential BNG. There are several within Sproughton parish that should be included.
4.32: Green borders should be included in this list, i.e. Hedgerows instead of Fences and walls.
Section 5:
5.1.1: Why not 15% if delivered on site and 25% if delivered elsewhere as mitigation to encourage green spaces in new development. This will appeal to developers as it will cost them less. Destroying existing biodiversity habitat and creating alternative habitat is disruptive and damaging to wildlife therefore the need for mitigation etc needs to be far greater than what is removed to ensure the eventual outcome is an improvement. If one acre of woodland is destroyed in one place the wildlife and all the associated biodiversity does not get on a bus to be transferred to a newly planted site elsewhere. There is going to be loss so the net gain planned needs to be greater to accommodate that loss and movement of as much biodiversity as possible needs to be managed and nurtured to re-establish as much as possible.
5.3.1: One issue is that the ecology reports required to identify the necessary species surveys normally have no local engagement – the local parish councils should be contacted to provide inormation. The desktop surveys looking for records are completely inadequate because the system of reporting is completely unknown to most people so virtually nothing actually gets reported. This is a flawed approach.
Any on site ecology survey is done by an expert but it is a brief site visit – a survey over several days would be more comprehensive. Typically, the ecology report for Chantry Vale / Wolsey Grange gave some information about potential birds but said there was no evidence of raptors when at that time just about every local knew that Kestrals were hunting for their chicks every day, in fact every minute of every day, in Chantry Vale. The Ecologist should be required to check with local Parishes or nature groups, because some species may not be present when the ecologist surveys the site, Some may be seasonal at a completely different time of year, some may be Transitory but regular visitors of a site that is important to their normal movements and some may just not be so obvious as to be picked up in a one day visit to a large diverse habitat site.
5.4.1: As above, the SBIS database is not particularly useful. For example the Taylor Wimpey (Wolsey Grange, Sproughton) ecologist used this over a period of 25 years for the WG site and the total number of reports submitted by the public amounted to less than a councillor saw as roadkill on the A1071 the week the ecologists report was published! It may identify a possibility to look for but the lack of any SBIS report about any biodiversity most certainly doesn’t exclude its presence. It just means no one has reported it. What is more the standard of report / verification / identification required is almost professional so even if a local resident were to see something really rare like a Pine Martin it probably wouldn’t make the report as an inaccurate / doubtful record. The principle of SBIS is good but in practice it is less useful due to minimal coverage. Local residents and Parish Councils have a far more detailed knowledge of their surroundings and are always overlooked until the surveys (which may be looking for the wrong biodiversity in the wrong place) have been completed. Early contact with parish councils is important their feedback should be included.
5.5.5: We agree with this although, there will be probably be quite a lot of debate over a parish councils view of a site, compared to some modelling by an ecologist claiming something else.
5.7: Although the scheme sounds reasonable the final conclusion essentially says building wherever wanted provided biodiversity is moved to a new site.
5.9.1 We are pleased that Babergh has included this point given the lack of action over the ripping out of the ancient hedgerow at Wolsey Grange, Sproughton.
