B&MSDC Supplementary Planning Documents Consultation

Comment

Representation ID: 23574

Received: 17/06/2024

Respondent: Natural England - Crewe

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.

Our remit includes protected sites and landscapes, biodiversity, geodiversity, soils, protected species, landscape character, green infrastructure and access to and enjoyment of nature.

While we welcome this opportunity to give our views, the topic this Supplementary Planning Document covers is unlikely to have major impacts on the natural environment. We therefore do not wish to provide specific comments, but advise you to consider the following issues:

Biodiversity enhancement
This SPD could consider incorporating features which are beneficial to wildlife within development, in line with paragraphs 8, 72, 102, 118, 170, 171, 174 and 175 of the National Planning Policy Framework. You may wish to consider providing guidance on, for example, the level of bat roost or bird box provision within the built structure, or other measures to enhance biodiversity in the urban environment. An example of good practice includes the Exeter Residential Design Guide SPD, which advises (amongst other matters) a ratio of one nest/roost box per residential unit.

Landscape enhancement
The SPD may provide opportunities to enhance the character and local distinctiveness of the surrounding natural and built environment; use natural resources more sustainably; and bring benefits for the local community, for example through green infrastructure provision and access to and contact with nature. Landscape characterisation and townscape assessments, and associated sensitivity and capacity assessments provide tools for planners and developers to consider how new development might makes a positive contribution to the character and functions of the landscape through sensitive siting and good design and avoid unacceptable impacts.

Protected species
Natural England has produced Standing Advice to help local planning authorities assess the impact of particular developments on protected or priority species.
Strategic Environmental Assessment/Habitats Regulations Assessment

A SPD requires a Strategic Environmental Assessment only in exceptional circumstances as set out in the Planning Practice Guidance here. While SPDs are unlikely to give rise to likely significant effects on European Sites, they should be considered as a plan under the Habitats Regulations in the same way as any other plan or project. If your SPD requires a Strategic Environmental Assessment or Habitats Regulation Assessment, you are required to consult us at certain stages as set out in the Planning Practice Guidance.

Should the plan be amended in a way which significantly affects its impact on the natural environment, then, please consult Natural England again.

Comment

Representation ID: 23577

Received: 17/06/2024

Respondent: Natural England - Crewe

Section 3.6.11 (Page 11)
We welcome point 4 regarding the need for measures such as Suitable Alternative Natural Green Space (SANGS) for larger-scale developments. It may be helpful to provide specific recommendations. As a minimum, for developments over 50 units, we advise that such measures should include:
- High-quality, informal, semi-natural areas
- Circular dog walking routes of 2.7 km within the site and/or with links to surrounding public rights of way (PRoW)
- Dedicated ‘dogs-off-lead’ areas
- Signage/information leaflets to householders to promote these areas for recreation
- Dog waste bins
- A commitment to the long term maintenance and management of these provisions

For guidance you can refer to Natural England’s Suitable Accessible Natural Green Space (SANGS) guidance (attached). Whilst this was produced for the Thames Basin Heaths Special Protection Area (SPA) it offers guidance that can be adapted to the requirements of Babergh & Mid Suffolk District Councils. It may also be helpful to refer to Natural England’s Green Infrastructure Framework.

Section 4 (Page 14)
Natural England welcomes the requirement for all development to follow the biodiversity mitigation hierarchy and explore opportunities to enhance or create benefits for wildlife. We welcome inclusion of the mandatory 10% uplift for biodiversity net gain (BNG) and that the Councils would encourage applicants to deliver a higher percentage of at least 20% BNG where possible. We welcome the emphasis on providing on site BNG as a preference and the reference to the Local Nature Recovery Strategy for off-site delivery. We agree with the proposed methodology for BNG.

Section 4.28 (Page 18)
We advise that Suffolk and Norfolk County Councils should be described as ‘Responsible
Page 2 of 2
Authorities’ rather than ‘Responsible Bodies’ in relation to Local Nature Recovery Strategies. The
designation of ‘Responsible Body’ means something different (relating to the overseeing of
Conservation Covenants).

Section 5.9.2 (Page 32)
We very much welcome the reference to the planting of heritage fruit trees from the local area.

Section 5.9.2 (Page 35)
We advise you may wish to consider using a different photograph of street trees that would better illustrate their value to an urban area.

Section 5.10.15 (Page 39)
In this paragraph, the sentence which reads “The benefits they provide, ecosystem services, also contribute to natural capital when assigned monetary values” might be clearer if it read: ‘The benefits they provide (i.e. ecosystem services) also contribute to…”

Section 5.10.15 (Page 39)
We advise you could consider including a reference to the Urban Tree Canopy Cover Standard (Green Infrastructure Standards for England, Natural England’s Green Infrastructure Framework).

Section 5.10.16 (Page 39)
We advise you could consider amending the wording in the first sentence to make the meaning clearer.

Section 5.11 (Page 39)
Natural England advises that maintenance of green infrastructure is equally as important as delivering it. We advise you to include reference to the importance of maintenance, and of establishing a mechanism for the maintenance, of any new green infrastructure that is created through new development as early as possible in the development process (rather than it being an afterthought). There must be an on-going source of funding for maintenance built into the project. While more details about this can be provided in the forthcoming Green Infrastructure Strategy, it should also be included in this piece of Supplementary Planning Guidance.

Comment

Representation ID: 23578

Received: 17/06/2024

Respondent: Natural England - Crewe

In section 5.3.9, which currently reads: “For small scale intensive livestock and poultry extension applications, where there are no identified sensitive receptors, it may be appropriate to use the ‘Simple Calculation of Atmospheric Impact Limits’ (SCAIL) model” we advise you could consider amending to the wording below:
“For small scale intensive livestock and poultry extension applications, it may be appropriate to use the ‘Simple Calculation of Atmospheric Impact Limits’ (SCAIL) model to screen the proposal for air quality impacts to nearby sensitive receptors of designated sites. However, if this shows that there may be a potential impact, detailed emissions modelling should be carried out.”