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Thank you for your email dated 01/06/2012 inviting Warwickshire Wildlife Trusts
comments on the above development plan. The Trust welcomes the opportunity to
participate in the ongoing development of the Warwick District New Local Plan and
would like to submit the following comments and recommendations for your
consideration.
PO4. Site Allocations
Warwickshire Wildlife Trust believes that further information is needed to inform and
justify the preferred housing allocations detailed in the new local plan. We are
concerned that the current evidence base and assessment criteria has not fully taken
account of all ecological constraints and opportunities for each allocation and
therefore cannot identify and isolate those housing options that offer the greatest
benefits for, or least impacts on, the natural environment. We recommend that the
local authority undertakes the following:
Update the evidence base
It is recommended that the Warwick District Habitat Assessment is updated to include
the additional 3 sites that were not initially reviewed under the 2008 assessment.
These sites are the land at Blackdown, Warwick Gates Employment Land and a site
that forms part of the Thickthorn allocation. The habitat assessment should aim to
ensure that up-to-date information on habitats, local sites and protected species
considerations are available for these additional three sites at this stage of the
planning process so that the relative constraints and opportunities of all preferred site
allocations are available to inform decision making. The National Planning Policy
Framework (NPPF) requires planning policies and decision to be based on up-to-date
evidence about the natural environment of the area so that the sustainability appraisal
can 'consider all the likely significant effects on the natural environment'. Therefore,
without comprehensive data for all preferred site allocations, it will be difficult for the
local authority to justify the conclusions of the sustainability appraisal process and
thus the preferred options during examination in public.
The Trust is aware that additional habitat assessment is underway for the land at
Blackdown and the site at Thickthorn; however we also recommend this is extended
to the Warwick Gates Employment land. Whilst we acknowledge that this site has
been previously allocated as an employment site in a previous local plan, we believe
that the site is still a preferred option and therefore needs to be supported by, and
assessed against up-to-date ecological evidence to justify its inclusion in the local
plan.
Clarify the Sustainability Assessment Criteria
The Trust recommends that the Sustainability Appraisal (SA) includes greater
transparency about the criteria used to assess different options and site allocations.
At present, it is not possible to determine how each site allocation was scored against
the 16 sustainability categories, which in turn raises questions as to how these
conclusions were formulated. In particular, we are concerned that for category 6: To
protect and enhance the natural environment of the SA, almost all the site allocations
have scored either a negative or strongly negative scoring, implying one of the
following:
- All site allocations are highly detrimental to the natural environment, in which
case the preferred housing options are collectively not an effective strategy to
deliver sustainable development in the district
- The environmental gains and benefits that new development can bring to a site,
through for example the protection and enhancement of valued ecological
features, green infrastructure delivery or habitat management, have not been
factored into the scoring assessment.
- The current criteria used for the natural environment is not sensitive enough to
differentiate between sites that can, on balance, provide opportunities for the
natural environment and those that can't. This could have occurred for example
by strong weighting towards factors such as the loss of the green belt, which will
always score negatively where development in the green belt is proposed.
The Trust would therefore like to see more information in the SA to justify why the
preferred development strategy has consistently shown negative scores for the
natural environment and how this development strategy can in turn contribute towards
the pursuit of truly sustainable development.
We believe the SA should detail a standardised and objective criteria for which all site
allocations should be assessed. This will give relevant stakeholders the opportunity to
review and comment upon the factors that influence the scoring for each site
allocation; helping to differentiate between the sustainability of different sites and
giving greater weight to the SA process overall. Using this feedback, the local
authority can then be confident that their chosen strategy represents the most
appropriate strategy when compared to all reasonable alternatives.
We believe that any scoring criteria for the natural environment should be inclusive of
both constraints and opportunities. This would ensure a more balanced approach to
scoring the natural environment category as impacts of each site allocations can be
considered in the context of other benefits and wider contributions to ecological
networks and biodiversity targets in the district. This approach is also more consistent
with the NPPF which requires local authorities to plan positively for ecological
networks in order to halt the loss of biodiversity by 2020. Subsequently, when scoring
site allocations for the natural environment, we recommend that the following factors
are taken in to consideration.
- Does the site impact on statutory and non-statutory wildlife sites
- Does the site impact on Local Biodiversity Action Plan (LBAP) habitats and
species and other important ecological features such as river corridors.
- Does the site have potential to impact on populations of protected species?
- Is there an ability to provide ecological mitigation to avoid or reduce long-term
impacts
- Are there opportunities for habitat enhancement, buffering statutory and nonstatutory
sites or introducing a management plan for sites, features or species of
ecological importance
- Are there opportunities to create, link-up or restore biodiversity and green
infrastructure assets across the district?
The Trust recommends that the impact on natural resources and ecosystem services
should also be considered within category 5: to ensure the prudent use of land and
natural resources of the SA. Currently this category is understood to be scored only
on whether or not the site allocation is on greenfield or brownfield land. However, this
does not take into account impacts on soils, air quality, natural resources or
ecosystem services. Nor does it consider what opportunities are available to mitigate
and enhance current natural resources and ecosystem services within site allocations
and how proposals could contribute to national targets and ambitions, such as those
listed in Biodiversity 2020: A Strategy for England's Wildlife and Ecosystem Services
for maintaining healthy and well functioning ecosystems and restoring degraded
ecosystems services. The Trust believes the impact on natural resources and
ecosystem services is a significant consideration in choosing site allocations and if
inadequately assessed could compromise the ability to achieve key objectives in the
plan or even the effectiveness of policy provisions. We subsequently recommend that
the site allocations are reviewed accordingly to account for these points.
Review Conclusions of Sustainability Appraisal
In light of our concerns above, we believe the local authority should review the scores
and conclusions given for category 5 and 6 of the sustainability appraisal. To aid this
process the Trust has briefly summarised a number of factors which we believe
should be considered for each preferred housing allocation. This summary is included
in appendix 1.
PO8. Economy
Warwickshire Wildlife Trust believes that it will be important for the local authority to
explore the case for including the proposed Warwickshire and Coventry Gateway
development area in the local plan. We are broadly supportive of the approach
detailed in paragraph 8.33 of the consultation document to review the impacts of the
proposal and believe this work will be essential if it is to be a justified allocation in the
plan. The Trust also recommends that in reviewing the impacts of the scheme, the
local authority should also take full account of the environmental and social
implications of including the allocation in the preferred options so that the economic
incentives of the scheme can be considered in the context of wider sustainability
objectives for the district. The evidence base for the natural environment will therefore
have to be reviewed and updated in order to inform the sustainability appraisal for this
site and any other reasonable alternatives that come forward as part of this review
process.
When considering the implications of all potential employment sites it will be
necessary to consider both the constraints and opportunities for the natural
environment. Having engaged in discussions about the Gateway proposals so far, the
Trust has identified numerous adverse effects on ecological assets but have noted
that the site also offers opportunities to deliver environmental enhancements in
strategic areas for green infrastructure and biodiversity, such as the River Avon LWS.
We believe the local authority needs to acknowledge and balance these factors so
that the impact on the natural environment on all site options can be more accurately
determined and assessed within the sustainability appraisal. Criteria for assessing the
constraints and opportunities of employment scheme on biodiversity should therefore
refer to the detailed criteria outlined above for housing allocations.
Any policy that favours a potential employment site of regional importance should
ensure that the enabling provisions reflect and are supportive of other themes in the
new local plan. The allocation should therefore embody the principles of sustainable
development by ensuring it contributes to wider economic, environment and social
objectives jointly. This should include improvements to green infrastructure and the
natural environment that are equivalent to the site's strategic importance so that it can
be seen as an exemplar for sustainable design and construction within the plan. In
order to optimise the potential for high quality environmental improvements, the Trust
strongly recommends that the policy wording should seek enhancements in line with
the district's ecological and green infrastructure networks, LBAP objectives for priority
habitats and species and Water Framework Directive objectives.
PO10. The Built Environment
The Trust is broadly supportive of the preferred option for the Built Environment. We
welcome the acknowledgement of the need to protect, enhance and link the natural
environment and would further support policy wording that recognises and promotes
the benefits of incorporating green infrastructure and suitable features for biodiversity
in and around development proposals. We believe that including these provisions,
together with links to other themes within the local plan, will help to underpin the
delivery of the Garden Suburbs prospectus and thus secure the district's ambitions to
promote high quality and sustainable development through the local plan.
PO12. Climate Change
The Trust is supportive of preferred option PO12 and in particular the local authority's
commitment to include a policy that promotes climate change adaptation. We
recommend that in wording this policy, due consideration is given to ensuring
linkages to delivering green infrastructure, protecting and enhancing biodiversity and
ecological networks and supporting objectives for mitigating and enhancing flooding
and water quality as these will all support and provide a context for delivering climate
change adaptations through new development proposals.
PO15. Green Infrastructure
Warwickshire Wildlife Trust welcomes the local authority's commitment to protect,
enhance and restore the district's strategic green infrastructure (GI) network. We
believe that the supplementary work to identify the network and the subsequent GI
projects that have informed the infrastructure delivery plan, provide a strong context
for securing mitigation and/or contributions towards GI enhancement within the new
local plan. Acknowledging the linkages with other themes such as Flooding and
Water, Climate Change and the Built Environment, GI should be considered an
integral part of good design and so we recommend that this is reflected in the wording
of an overarching green infrastructure policy. This has already been reflected in part
under the 'Development Proposals' paragraph in PO15 which would in turn create an
excellent starting point for the policy wording.
The Trust is pleased to note Warwick District's intention to adopt the sub-regional
green infrastructure SPD. This provides an excellent opportunity to secure strategic
improvements to priority ecological networks throughout Warwickshire, Coventry and
Solihull which will in turn strengthen and compliment existing district wide and local
networks. Maintaining the reference to each level of the strategic green infrastructure
network will ensure that contributions to achieve these aims can be secured; thus
demonstrating the district's commitment to planning positively for networks of green
infrastructure. However it may be necessary to clarify how and when improvements to
the different networks will be sought and the mechanism that will be used to balanced
how these contributions are distributed between the local, district and sub-regional
networks accordingly.
Our concern with the preferred option so far is the coupling of a green infrastructure
policy with the protection and enhancement of biodiversity. Whilst we agree that sites,
features and corridors of wildlife importance do form an integral part of local, strategic
and sub-regional GI networks, we believe that a GI policy cannot deliver the robust
and objective protection for biodiversity assets that could normally be set out within a
specific biodiversity policy. The NPPF set outs a good criteria based approach for
protecting statutory and non-statutory sites. It requires policies to differentiate
between sites of national and local importance so that their protection is
commensurate with their status and the contribution they make to wider ecological
networks. For local sites this criteria based protection is essential as it clearly defines
the level for which it remains robust when challenged by development interests.
Conversely, the multifunctional nature of GI makes it difficult to specify a criteria
based approach for its individual components and so blanket protection must be
applied to safeguard all assets. Whilst in principle, absolute protection is an ideal; the
Trust recognises this is likely to be less effective as it makes it much more vulnerable
to challenges from development interests. Subsequently, whilst maintenance and
enhancement of ecological networks should still be pursued through a green
infrastructure policy, we believe that a specific biodiversity policy is also needed to
ensure a sufficient level of protection for sites, features and habitats of biodiversity
importance. Our policy recommendations for biodiversity are discussed below.
POXX. Biodiversity
Warwickshire Wildlife Trust strongly recommends that the preferred option includes a
policy to specifically outlining the protection of the district's biodiversity assets.
Referring to our comments above, we do not believe that a green infrastructure policy
in isolation can provide an adequate level of protection for individual biodiversity
assets within the district. A biodiversity policy, founded on the criteria based approach
detailed in the NPPF, is considered to be a more effective approach as it:
- ensures that protection is commensurate with the site or feature's status and
contribution towards wider ecological networks,
- provides greater clarity as to how impacts on biodiversity assets will be judged
therefore proving to be more robust when challenged; and
- can specifically promote the preservation, restoration and re-creation of priority
habitats, ecological networks and the protection and recovery of priority species
populations in line with national and local targets.
Ensuring robust protection for biodiversity assets should be considered as a priority
when planning positively for ecological networks. Statutory and non-statutory sites,
particularly Local Sites, provide the fundamental building blocks for establishing
ecological networks. With these sites only constituting approximately 3% of the entire
district area, it will be essential that these core features are effectively secured.
However, important biodiversity assets are not simply confined to these areas and so
it will be necessary to ensure that the policy outlines a degree of protection for other
important biodiversity features that do not benefit from a statutory or non-statutory
designation, such as wildlife corridors, LBAP habitats and species and linear features
such as hedgerows and watercourses.
The Trust therefore believes that the strong protection of statutory and non-statutory
sites and other features of ecological importance should form an integral part of a
biodiversity policy within the local plan. In order for this policy to be effective, we
support the criteria based policy approach detailed in the NPPF as this clearly
outlines the relative weight given to each site, feature and habitat so that protection is
commensurate with its status and the to the contribution it makes to wider ecological
networks. However, as the criteria must differentiate between national and local
designations we believe that the policy should include separate policy clauses for
sites of International importance (SAC, SPA, Ramsar), national importance (SSSI),
county importance (LWS, LNR) and features of district/county importance (LBAP
habitats and species, wildlife corridors).
Where impacts on features of nature conservation importance are identified, it will be
necessary to outline how impacts can be resolved to prevent a net loss of
biodiversity. Paragraph 118 of the NPPF provides a useful hierarchy of how impacts
should be dealt with in this instance. It requires that all adverse impacts on
biodiversity should be avoided first, then if impacts cannot be avoided, and the
reasons for the development demonstratably outweigh the nature conservation
importance of the site or feature, mitigation should be secured. Compensation should
only be sought as a last resort. The Trust would advise that this categorical approach
to dealing with biodiversity impacts is adopted into a biodiversity policy for the local
plan. We also believe that a reference to Biodiversity offsetting should be included at
this stage of the policy (As opposed to including it in the green infrastructure policy)
so that if compensation is sought for a development, then the district can demonstrate
that it has an objective mechanism for ensuring that the proposal will not result in a
biodiversity loss. References to the sub-regional and district GI strategies, together
with the proposals for a Nature Improvement Area or the results of any Biodiversity
Opportunity Mapping, should be included here to outline how the biodiversity
offsetting process contributes towards delivering strategic gains for biodiversity.
However, biodiversity offsetting is a means to quantifying biodiversity impacts that
cannot addressed on site and so it should be clearly outlined that this process is a
last resort where adverse impacts cannot be avoided or mitigation for on site.
The Natural Environment White Paper has outlined that the UK needs more, bigger,
better and joined places for nature to reverse the continual loss and decline of
biodiversity and essential ecosystem services. This policy should therefore form the
basis for securing biodiversity gains through the planning system in order to
contribute towards the Government's ambitious target of halting the loss of
biodiversity by 2020. To transpose these targets and policies in to the District's local
plan, it will be necessary for the biodiversity policy to also include some provision for
enhancing biodiversity as well as protecting it. This could be achieved, for example,
by promoting habitat creation, restoration, re-creation and/ or management of existing
features within all new development proposals. Whilst a green infrastructure policy
goes some way towards this provision, it is non-specific to biodiversity and cannot
guarantee that improvements to the network deliver these crucial gains for
biodiversity. The Trust believes a policy clause could be included in the biodiversity
policy as means to securing these aims.
Warwickshire Wildlife Trust would welcome the opportunity to input into, or comment
on, any policy wording that is developed for a specific biodiversity policy in the new
local plan.
PO17 Tourism and Culture
The Trust believes that policies that support sustainable tourism should be
encouraged providing that they truly reflect the principles of sustainable development.
New sustainable tourism developments should therefore be able to detail how they
safeguard and contribute towards the enhancement of biodiversity assets, the water
environment and green infrastructure whilst demonstrating high quality and
sustainable design and construction throughout. The Trust would subsequently
welcome a clause within a sustainable tourism policy linking it to wider themes within
the local plan to clearly define what 'sustainable' tourism should be expected to
achieve.
PO18. Flooding and Water
The Trust are broadly supportive of the preferred option for flooding and the water
environment; however we believe that PO18 is lacking in detailed provisions for
safeguarding and enhancing water quality and optimising opportunities to reduce
flood risk by linking with themes such as green infrastructure, biodiversity and the
built development.
The need for stronger controls on protecting and enhancing water quality is outlined
in paragraphs 18.12 - 18.14 of the consultation document. It details that only 11% of
water bodies in the district are at 'Good' ecological status and so the district must
employ an ambitious approach to tackling water quality issues within the local plan if it
is to achieve the objectives of the Water Framework Directive by 2015. Development
can contribute to towards improving water quality though a number of means such as
SUDS, buffering watercourses and reconnecting them with their floodplains, creating
new wetland habitats and retrofitting measures that assist with attenuating and
filtering surface water before it is discharged into water bodies. The Trust therefore
recommends that such measures are strongly promoted in all new developments so
that provisions to safeguard water quality are also pursued in tandem with
opportunities to mitigate and enhance them. Policy wording that would support this
approach would be strongly welcomed by the Trust
The Trust recognises and supports the district's commitments for preventing new
development within flood risk zones in order to reduce future flood risk issues.
However, we believe that this approach should be the minimum requirement for
reducing flood risk as there is also a need to mitigate against existing flood risks and
adapt to the to changes in river levels that are likely to occur as a result of climate
change. The Local Authority should therefore be planning positively for addressing
flood risk, promoting opportunities not only to incorporate SUDS but to reconnect
rivers with their natural flood plains and support the creation of new wetland and
riparian habitats thoughout the district. The Trust acknowledges and welcomes the
district's strategic green infrastructure proposals adjacent to the River Leam which will
ensure that contributions for new development can be strategically placed; however
these principles should be embodied into policy wording so that wider opportunities to
reduce flood risk can be pursued. Where possible, opportunities to reduce and adapt
to food risk should be included in the scoring criteria in the SA for flooding as well as
determining whether or not the allocations is within the flood plain.
I hope these comments are useful to you as you progress the development plan
through to the next stages. Please do not hesitate to contact me if you seek further
clarification on any of the above points.
Yours sincerely
Richard Wheat
Planning and Biodiversity Officer
Warwickshire Wildlife Trust
Appendix 1: Summary of factors that should be considered when scoring site
allocations against Category 6 in the Sustainability Appraisal
Site Name Summary of ecological comments for the scoring
criteria described above
Woodside Farm
(South of Whitnash)
The small section of broad-leaf woodland and the mature
hedgerows and trees are the key features of this site. However
there are opportunities to retain these features and enhance
them through buffering or new habitat creation which should be
reflected in the score for this site.
Whitnash East
(South of Sydenham)
Whitnash brook, which forms the eastern boundary of the site, is
an important watercourse and wildlife corridor that supports a
good variety of semi-natural habitats and connects to the
adjacent Local Nature Reserve in the north. The development
area also supports hedgerows which connect the feature to the
Railway cutting to the east which is a pLWS. The presence of
protected species will also need to be considered and so overall
this site could score unfavourably on these grounds. Scoring
should take into account that impacts on the brook could be
avoided and mitigated through a substantial buffer and the
hedgerows could be retained to maintain connectivity to the
adjacent pLWS. There is also an opportunity to extend the
existing LNR boundary south along the eastern boundary of the
site by buffering the brook and delivering further habitat
enhancement, creation and restoration on site.
Fieldgate Lane
(Whitnash)
Species rich hedgerows and the adjacent railway pLWS are the
key ecological features for this site. The grassland habitat that
constitutes much of the site contains ridge and furrow, but is
species poor and offers opportunities for enhancement. The site
offers excellent potential to buffer the railway pLWS and retain
the hedgerows which are confined to the site boundaries. It also
provides opportunities for habitat restoration and creation on
site.
South of Gallows Hill/
West of Europa Way
The linear belt of habitats following the Tach Brook is an
important and sensitive feature of the site. Some of these
habitats also form part of Nursery Wood pLWS and connect well
with New Waters LWS and so the site should score
unfavourably on these grounds. Numerous hedgerows and trees
are also present throughout the site, providing opportunities for
protected species such as otter. This will need to be reflected in
the scoring for this site. The Tach brook corridor with associated
semi-natural habitats could and should be substantially buffered
and maintained in order to retain this important connective route
throughout the site. Buffering along the Nursery wood pLWS
boundary to the west could also be achieved as part of any
landscaping proposals to maintain linkages. Hedgerows and
mature trees could also be retained although there is likely to be
some loss to provide access across the site. The site offers
good potential to deliver habitat creation, restoration and
enhancement particularly around the Tach brook area and
improve connectivity to surrounding sites, features and habitats.
Myton Garden Suburb
(North of Gallows Hill)
The presence of a biodiverse watercourse, veteran trees,
mature hedgerows, ridge and furrow grassland and a good
likelihood of protected species are likely to score this site
unfavourably. However, there are opportunities to retain
important hedgerows and trees and buffer and enhance the
watercourse as well delivering new habitat creation or
restoration on site. The watercourse could provide linkages to a
strategic wildlife corridor in the form of the River Leam
Loes Farm
(North of Woodloes)
The Veteran Oaks, watercourse and old semi improved
grassland with yellow meadow ants are important and unique
ecological features that according to the WDC Habitat
Assessment are a significant constraint to the development at
this site. As much of the site constitutes the old meadow it would
be impossible to deliver even small amounts of development
without adversely affecting these key features and so the site
should score unfavourably on these grounds. If impacts can be
minimised, there may be opportunities to enhance the
watercourse and the plantation woodland on site and improve
the current botanical diversity of the grassland
Red House Farm
(East of Lillington)
The Hedgerows are perhaps the key feature of the site, together
with the opportunities they provide for protected species.
However there are opportunities to retain the hedgerows as well
as potential to deliver habitat creation and restoration throughout
the site.
Land North of Milverton The brook corridor which is a tributary of the River Avon LWS,
the area of semi-improved grassland to the southeast and the
species-rich mature hedgerows and trees are all key features for
the site. The layout of the hedgerows would likely make it
difficult to retain the vast majority of these features and so
should be scored unfavourably on these grounds. Removal of
these features and the any associated mature trees would also
likely disrupt habitat opportunities for protected and noteworthy
species such as farmland birds and bats. Otters may also be a
consideration. There are opportunities to maintain and buffer the
brook corridor in the northeast of the site enhancing linkages to
the River Avon which is a strategic green infrastructure asset.
There are also opportunities for new habitat creation, restoration
and enhancement throughout the site.
Thickthorn (Inc Land
north of Thickthorn)
The section of Thickthorn wood LWS within the site boundary,
the adjacent Glasshouse Spinney LWS, the mature hedgerows
and trees and an area of semi-improved grassland are all likely
to be constraints to development at this site. There are
opportunities to retain and buffer these key ecological features
but there is a risk that infill development in this area will further
isolate or restrict connectivity to and between these features.
Scoring should reflect this cumulative impact. Opportunities for
new habitat creation could help reduce these impacts by linking
up the woodlands as well as contributing towards wider
enhancements to the Arden Landscape area.
More information is needed about the habitats north of
Glasshouse Spinney to provide a more comprehensive
summary for this site.
Land at Blackdown Up-to-date ecological data required
Warwick Gates
Employment Land
Up-to-date ecological data required