Testun llawn:
New Local Plan Preferred Options Consultation
1. Thank you for your consultation dated 1 June 2012, which we received on the same date. Thank you for allowing additional time in which to respond. This enabled our submission to be compiled with the benefit of some input from locally based colleagues.
2. 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.
Overview
3. There is much to commend within the consultation document in terms of protection and enhancement of the natural environment. We have relatively few comments to make but would like to raise a small number of potential areas of concern and possible improvement.
4. We assume the numbered preferred options presented in the mauve boxes foreshadow policies content rather than representing proposed policy wording. For that reason have not recommended any detailed changes to text but have confined ourselves to broader observations.
Detailed comments
Section 2.5 Strategy for the Future and Sustainable Prosperity of Warwick
District
5. We support the fourth bullet under "environment" and second bullet under "emphasis on infrastructure" which pick up on the importance of protecting and enhancing of the natural environment. It is important that the final version of the plan follows through on these important components of the vision. In line with the NPPF requirement (paragraph 157) that
Section 4.12 Enabling the district's infrastructure to improve and support growth
6. We welcome the reference (objective 14) to enabling improvements to be made to the built and natural environments which will help to maintain and improve historic assets, improve habitats and their connectivity, help the public access and enjoy open spaces such as parks and allotments, reduce the
risk of flooding, keep the effects of climate change (including the effects on habitats and wildlife) to a minimum, and support healthy lifestyles. This should help to translate the requirements of the NPPF into practice and is welcome recognition of some of the multiple ecosystem and other benefits that the natural environment and green infrastructure delivers for communities.
PO2: Community Infrastructure Levy
7. Natural England recognises that CIL has a part to play in providing the infrastructure that new and existing communities will need. Green infrastructure is a part of the essential necessary to support growth and we trust the Council will ensure that the need to make provision for key green infrastructure
PO3: Broad Location of Growth
8. Natural England is concerned that the overall level and spatial distribution of growth should be informed through detailed environmental testing. From that perspective we welcome the Sustainability Appraisal work undertaken so far and the fact that the allocations have avoided direct impact upon statutory biodiversity designations.
9. We do note that a number of preferred allocations (e.g. Whitnash East) incorporate, or are bounded by, Local Wildlife Sites and/or Local Nature Reserves and would encourage the Council to ensure that sufficient safeguards could be incorporated before confirming these allocations.
10. Similarly, a number of the preferred allocations (e.g. West of Europa Way) lie adjacent to Warwick Castle Park . This site is not subject to any natural landscape or biodiversity designation but is the subject of a Higher Level Stewardship agreement to maintain and improve its environmental value. We would like to ask whether the Council will consider the potential for indirect impacts on the Park (e.g. of increased recreational pressure) and degree to which these can be moderated before confirming these allocations?
PO10: Built environment
11. We welcome inclusion of the intention to protect, enhance and link the natural environment through policies to encourage appropriate design of the built environment. We also welcome the intention to set out a framework for subsequent more detailed design guidance to ensure physical access for all groups to the natural environment. The natural environment and access to it are important aspects of urban design that have been overlooked in some areas in the past.
PO13: Inclusive, Safe & Healthy Communities
12. The third and fourth bullet points are supported, provided a proportion of the new open spaces provided as part of new development are made up of accessible natural green spaces with all the associated health and wellbeing benefits. Natural England promotes an Accessible Natural Greenspace Standard1 that we encourage local authorities to adopt.
PO12: Climate Change
13. Natural England welcomes measures to tackle climate change which is the greatest long term threat to the natural environment. None the less, we look to plans to take full account of the local natural environment to accommodate such infrastructure. In particular, we encourage plan makers to identify areas for different forms of low carbon energy and to ensure that designated landscapes are fully protected.
14. The intention to require that new development is designed to be resilient to and adapt to the future impacts of climate change in welcome. We particularly support the reference to the use of greenspace and vegetation, (such as street trees) to provide summer shading and allowing winter solar gain.
PO15: Green Infrastructure
15. We support the preferred option relating to green infrastructure, which is consistent with the NPPF (paragraph 114). We particularly welcome the recognition that this exists and can be supported through planning at a variety of spatial scales.
16. We would expect the final pan to include more specific detailed policies on certain aspect of green infrastructure. For instance, we trust that policies for biodiversity will extend beyond offsetting to cover the landscape scale approach, net gain, ecological networks, designated sites and priority and protected species.
17. Similarly, the references to geology, soils and ecosystem services are welcome and we would expect that these matters will translate into robust policy content within the final plan.
PO16: Green Belt
18. We support the reference to positively enhance the beneficial use for the Green Belt, such as looking for positive opportunities to provide access; to provide opportunities for outdoor sport and recreation; to retain and enhance landscapes, visual amenity and biodiversity or to improve damaged and derelict land. This is an aspect of Green Belt that has not always been afforded an appropriate degree of attention in all areas.