Issue and Options 2023

Ended on the 6 March 2023

11: A biodiverse and environmentally resilient South Warwickshire

Chapter 11 sets out various options regarding landscape, environment and natural resources. Your views are sought on the following issues:

Strengthening green and blue infrastructure and achieving a net increase in biodiversity across South Warwickshire is a key component to creating a sustainable development plan, and with Central Governments ambition to help the natural world regain and retain good health it is important that this objective is considered throughout the development process. This local plan objective seeks to protect environments that already exist, and to maximise the opportunities for enhancement through various means. The most substantive of which includes the proposed Environmental Net gain approach, which would be the first of its kind within a Local Development Plan. The benefits of a biodiverse and environmentally resilient South Warwickshire extend beyond just the environmental benefits, with the climate, economy, flooding, health, and wellbeing also known to benefit from a thriving natural world.

This section also considers area designations that consider landscape, character, and setting, and other important environmental issues such as minerals and agricultural land.

Issue B1: Areas of Restraint

Areas of restraint are another designation specific to Stratford-on-Avon District. They are not considered landscape designation but are designed to protected areas of open land which serve to preserve the structure and character of various settlements. These areas can include relatively small, or larger areas within or adjacent to settlements and their overriding purpose is to protect the inherently open nature of certain areas. Areas of Restraint are not referenced within the National Planning Policy Framework however are used within the Core Strategy to show the importance of open land within and around urban areas.

To ensure a consistent approach across the plan area a single approach is desirable. Up to date landscape evidence will be used to inform decision making on this issue.

Current Adopted Policy

Policy document	Policy reference	Page no.	Policy Summary
Stratford-on-Avon District Core Strategy	CS.13	79	Land designated as an Area of Restraint makes an important contribution to the character of the settlement. Development must not harm or threaten the open nature of such areas, taking into account any possible cumulative effects. Planning permission for a large-scale form of development in an Area of Restraint will only be granted where a scheme would have demonstrable community benefits and contribute significantly to meeting an objective of the Core Strategy. It will also need to be demonstrated that no suitable alternative site outside the Area of Restraint is available for the proposed development. Projects which enhance the character and visual amenity of Areas of Restraint will be encouraged, as will the promotion of beneficial uses such as public access, nature conservation and food production.
Warwick District Local Plan	N/A	N/A	N/A

(114) Q-B1: Please select the option which is most appropriate for South Warwickshire

Issue B2: Vale of Evesham Control Zone

The Vale of Evesham Control Zone seeks to control the number of additional HGV movements within the area resulting from development, thereby reducing the impact on local communities. The Policy is only relevant to Stratford-on-Avon District as the Vale of Evesham does not extend into Warwick District. The Vale of Evesham Policy is reliant on collaboration with the neighbouring districts of Wychavon and Cotswolds, for it to work effectively. The existing Local Plans of Wychavon and Cotswold District Councils both contain a similar policy on the Vale of Evesham Control Zone. However, both Districts are reviewing their local plans and there is a question as to whether policies on the Vale of Evesham Control Zone will be carried forward. Should the bordering Districts not decide to carry the Vale of Evesham Control Policy Forward there would be little merit in maintaining the policy within the South Warwickshire Local Plan.

Current Adopted Policy

Policy document

Policy reference

Page no.

Policy Summary

Stratford-on-Avon District Core Strategy

CS.14

Within the Vale of Evesham Control Zone business-related proposals which would result in a 5% or greater increase in Heavy Goods Vehicles traffic will need to demonstrate that:

the economic benefits of the development, particularly to the local community, outweigh the impact of the increase in HGV traffic;
the development cannot be accommodated on a site with better access to the Heavy Goods Vehicles Route Network
the supply and distribution routes proposed to serve the development are the most appropriate with regard to impacts on the amenity of local communities.

Warwick District Local Plan

N/A

(60) Q-B2: Should the Policy on the Vale of Evesham Control Zone be removed, if neighbouring authorities decide not to carry the designation forward?

Issue B3: Special landscape areas

What you said:

The scoping and call for sites consultation did not include a question on Special Landscape Areas, however there was a general consensus that people feel strongly about the protection and enhancement of landscape areas, with concerns about development negatively impacting the landscape.

Special Landscape Areas are another landscape designation specific to Stratford-upon-Avon District. Special Landscape Areas are areas of high quality landscape, that also contain associated historic and cultural features. SLA's seek to protect, enhance and facilitate better management of the best of the area's landscapes outside the Cotswolds AONB. Development within the Special Landscape Areas therefore needs to be considerate of its surrounding landscape and not have a harmful impact on the distinctive character or appearance of the area. Stratford-upon-Avon's Special Landscape Areas were determined during the creation of the Core Strategy following the information provided through the Special Landscape Area Study (2012) and drawing upon information found within the National Landscape Character Area profiles. The information within this study can now be considered out of date, so should there be appetite to carry this designation forward, an updated study would need to be undertaken.

Special Landscape areas are not encouraged within England through national policy or through Natural England's approach, as was also the case in 2012. Despite this, it was still felt that there was merit in designating Special Landscape Areas and there are a number of other Councils that have opted to maintain Special Landscape Areas, including Cotswold District Council to which South Warwickshire shares a boundary. Given the rural nature of South Warwickshire and the unique landscape characters across the area, it is important that development is considerate of the local vernacular. Should Special Landscape Areas not be carried forward, it would be necessary to protect existing landscapes through other means.

Current Adopted Policy

Policy document

Policy reference

Page no.

Policy Summary

Stratford-on-Avon District Core Strategy

CS.12

The high landscape quality of the Special Landscape Areas, including their associated historic and cultural features, will be protected by resisting development proposals that would have a harmful effect on their distinctive character and appearance. The following Special Landscape Areas are identified:

Arden
Cotswold Fringe
Feldon Parkland
Ironstone Hills Fringe

Development proposals relating to settlements that lie within a Special Landscape Area must respect the current and historic relationship of that settlement within the landscape.

Warwick District Local Plan

N/A

(133) Q-B3: Please select the option which is most appropriate for South Warwickshire

Issue B4: Protecting the Cotswold Area of Outstanding Natural Beauty (AONB) and its surrounding areas

Terminology

In recent years there has been a shift in the terminology used when discussing the Cotswold Area of Outstanding natural Beauty (AONB). Whist the Cotswold AONB remains the formal name for the designation, Cotswold National Landscape is a commonly used alternative. Both names refer to the same designation, and are often used interchangeably. For the purpose of this local plan the term Cotswold AONB will continue to be used.

The Cotswold Area of Outstanding Natural Beauty (AONB) covers 104km of the Local Plan Area, and already affords a significant amount of protection through the National Planning Policy Framework. When considering development in and around the Cotswold AONB, regard should be given to conserving and enhancing the natural beauty of the area. In particular, great weight should be given to conserving and enhancing the landscape and scenic beauty, including its 'special qualities'. This includes development proposals within and outside the AONB that could have an adverse impact on its natural beauty. This includes impacts on views from and to the AONB, landscape character and tranquillity. Any development also needs to consider the policies as set out in the Cotswold AONB Management Plan.

The use of a buffer around the AONB would ensure that due regard is given to potential impacts of development outside the AONB, on the beauty of the AONB as well as its setting, and to ensure that great weight is given to these impacts, where appropriate, in line with paragraph 176 of the NPPF.

Current Adopted Policy

Policy document	Policy reference	Page no.	Policy Summary
Stratford-on-Avon District Core Strategy	CS.11	74	Development proposals affecting the Cotswolds AONB should conserve and enhance the special landscape qualities and scenic beauty of the AONB and be consistent with the objectives set out in the Cotswolds AONB Management Plan. The parts of the AONB that lie within the plan area are defined as 'tranquil areas' where the minimisation of noise, traffic congestion and light pollution is a priority. Large scale development will not be allowed unless exceptional circumstances and public interest are demonstrated in accordance with all the criteria set out in the National Planning Policy Framework.
Warwick District Local Plan	N/A	N/A	N/A

(73) Q-B4: Please select the option which is most appropriate for South Warwickshire

Issue B5: Environmental Net Gain

What you said:

Support for the protection and enhancement of our green areas and associated habitat/biodiversity, and for this to include appropriate compensatory measures.
Prioritisation of the mitigation hierarchy
Concerns that compensatory measures are not adequate, and that development should be directed to brownfield sites where compensatory measures are not required,
Many noted how compensatory measures and any net gain needs to be proportionate, justifiable, viable and deliverable

Natural Capital

The elements of nature that directly or indirectly produce value to people, including ecosystems, species, freshwater, land, minerals, the air and oceans, as well as natural processes and functions

(National Capital Committee 2017)

Historically, national guidance and Local Plans, by following the mitigation hierarchy (Figure 25), have focused on protecting, and limiting negative impacts on protected sites and species. This has largely been achieved through Biodiversity Net Gain (BNG) where developments are required to compensate for any impacts on habitat either through enhancing existing habitats or creating new ones (if impacts are unavoidable). This compensation can take place either on or off-site. Biodiversity Net Gain used to be discretionary and at a Local Authorities request, however, the new Environment Act has made a 10% Biodiversity Net gain a statutory requirement. Biodiversity net gain, however, only focuses on one aspect of nature's recovery. As such, since 2012 there has been a shift towards Environmental Net Gain, which covers a broader scope and is delivered though nature-based solutions.

Supported within the Government's 25 Year Environment plan, environmental net gain is an approach to development that leaves the environment in a measurably better state than prior to development. It looks holistically at various ecosystem services including air quality, water quality, carbon offsetting and biodiversity, and addresses these in tandem to enhance the wider 'natural capital' of an area. The 4 ecosystem services that Environmental Net Gain could include are explained below

Table 15 – The 4 ecosystem services that Environmental Net Gain could include

Air Quality

Sometimes development can impact air quality, which can negatively affect peoples' health. Air quality can be improved using natural solutions such as trees and green roofs, and can also be addressed physically by ensuring dwellings and other buildings, such as schools, are suitably positioned/protected from high concentrations of poor air quality, either through distance or natural barriers such as hedges.

Water Quality

Water quality can sometimes be affected following development, for example through surface water runoff. Flooding and poor drainage systems can also impact water quality. Beyond ensuring development does not result in an increased risk of flooding, a number of solutions such as suds and rain gardens, can be used to maintain and improve water quality.

Carbon offsetting

Some developments may not be able to completely neutralise their carbon emissions and in these cases a carbon offsetting approach could be developed. This could include natural solutions such as the planting of trees to absorb carbon, or more developmental solutions such as funding existing housing stock to be retrofitted to help reduce the overall carbon emissions across the plan area.

Biodiversity

Some developments are unable to avoid negative impacts on local habitats and wildlife, and in these instances a biodiversity net gain is required. Biodiversity net gain can be achieved in many ways, including through natural solutions (e.g creating new and improved habitats or utilising SUDS) to more physical solutions such as bird boxes and hedgehog holes.

In assessing the approach of Environmental Net Gain in relation to infrastructure, the National Infrastructure Commission identified many benefits, including:

supporting natural capital by mitigating against climate change and flood risk, improving air and water quality, and improving quality of life
delivering benefits efficiently, for example both achieving an infrastructure goal and increasing resilience
saving time and money by avoiding the risks of costly and lengthy appeals processes due to environmental concerns
being a positive approach that ensures losses in high value natural capital are minimised and mitigated while also providing opportunities to enhance natural capital, given that biodiversity loss is hard to reverse.

The benefits of environmental net gain are considered to be superior to those achieved through biodiversity net gain alone, given the wider scope of environmental enhancement, and the additional benefits for people. There is not yet an agreed assessment or approach to achieve environmental net gain, which provides an exciting opportunity for South Warwickshire and the South Warwickshire Local Plan. Already adept at biodiversity offsetting, South Warwickshire, in partnership with the County Council, has valuable knowledge and resources that make it a suitable forerunner in this approach. It is possible that there may be various ways to approach environmental net gain, and with the variety of ecosystem services involved it may provide more flexibility to developers as well as enhanced benefits for the environment, people, and the economy. Whilst caution needs to be taken to prevent a negative 'tradeoff' between ecosystem services, it may be that where some sites are constrained in one sense, they are able to make up their environmental net gain in other areas, helping with viability issues and other constraining factors such as space. This will not however, be to the detriment of a 10% Biodiversity Net Gain, which will still be a minimum requirement under the Environment Act.

There is much work to be done to explore environmental net gain further, and this has been supported through the Natural Environment Investment Readiness Fund project, which seeks to explore polices, investment opportunities and market establishment. The findings from this report demonstrate that such an approach would have a far superior impact than the current system, and help South Warwickshire reach net carbon zero and other demonstrable environment gains.

Figure 25 - Mitigation Hierarchy

Inverted triangle, from top (largest) to bottom: Avoid, Reduce, Replace, Compensate (Offset), Neutralise (Remove).

Current Adopted Policy

Policy document	Policy reference	Page no.	Policy Summary
Stratford-on-Avon District Core Strategy	CS.6	48	Development will be expected to contribute towards a resilient ecological network throughout the District that supports ecosystems and provides ecological security for wildlife, people, the economy and tourism. Biodiversity Net gain is encouraged, however reducing the impacts of development on biodiversity is considered the priority. Existing habitats to be protected include: Sites of Special Scientific Interest (SSSI's) Irreplicable habitats such as Ancient Woodlands Designated sites including Local Wildlife Sites and Local Nature reserves Non-designated sites that are known to make a positive contribution to biodiversity Areas that comprise or host habitats and species of principle conservation importance Developments that are likely to have an adverse effect upon a site designated through the EC Habitats Directive or Birds Directive will not be permitted.
Warwick District Local Plan	NE2	118	Designated areas and species of national and local importance for biodiversity and geodiversity are protected: - Sites of National Importance - Sites of Local Importance: Ancient Woodland, aged and veteran trees; Local Nature Reserves; Local Wildlife Sites and potential Local Wildlife Sites; Local Geological Sites; Protected, rare, endangered or priority species or other sites of geological or geomorphological importance. Unless it can be demonstrated that the benefits of development clearly outweigh the nature conservation value or scientific interest of the site.
Warwick District Local Plan	NE3	119	New development will be permitted provided that it protects, enhances and / or restores habitat biodiversity. Development proposals will be expected to ensure that they: lead to no net loss of biodiversity, and where possible a net gain protect or enhance biodiversity assets and secure their long term management and maintenance, avoid negative impacts on existing biodiversity. Where this is not possible, mitigation measures must be identified. If mitigation measures are not possible on site, then compensatory measures involving biodiversity offsetting will be required.

(119) Q-B5: Please select the option which is most appropriate for South Warwickshire

Issue B6: Wildbelt designations

Wildbelt is a new approach to aiding Natures Recovery that looks at designating land specifically for environmental enhancement. The wildlife trusts are currently striving to ensure that by 2030, 30% of our land and seas are managed for natures recovery, and believe that whilst there are many designations protecting areas of environmental importance, there are no designations for areas of land in need of improvement. Wildbelts therefore seek to identify and designate areas of land with currently low biodiversity value, and protect them whilst the necessary work is undertaken to support natures recovery, either through creating new habitats or bringing nature back. Such areas for Wildbelt designation could include agricultural land that is being reverted to species-rich grassland; land in local communities that's being managed to enhance its biodiversity and give people more nature on their doorstep, or lengths of grass verges that could be enhanced to help create corridors for wildlife. The idea of Wildbelts is that it protects the space that nature needs for the future.

Wildbelts would work alongside existing designations, such as National Parks and SSSI's, and could be used to help connect existing areas of ecological importance to one another, as well as helping to speed up the creation of Local Nature Recovery Strategies, as land and space has already been reserved for such enhancement. More detail on Wildbelts, and other actions the Wildlife Trusts support can be found in their report 'Planning – A new way forward'

As this is a new approach, promoted by Wildlife Trusts and supported by Government, neither the Stratford-on-Avon Core Strategy nor the Warwick Local Plan have existing policies of this nature. The introduction of Wildbelt designations would be new and pioneering.

Current Adopted Policy

Policy document	Policy reference	Page no.	Policy Summary
Stratford-on-Avon District Core Strategy	N/A	N/A	N/A
Warwick District Local Plan	N/A	N/A	N/A

(121) Q-B6: Should the South Warwickshire Local Plan introduce Wildbelt designations?

Issue B7: Minerals

Warwickshire County Council produces a Minerals Plan, which includes policy regarding mineral safeguarding and extraction. The Minerals Plan defines broad 'safeguarding areas' for different types of mineral reserves, and policy in the plan seeks to avoid needless sterilisation of these reserves by large scale development. The Minerals Plan also allocates specific sites where mineral extraction is intended. Stronger policy relates to allocations, to ensure that development on or near the allocated sites does not prevent extraction of the mineral resource.

Current adopted policy

Policy document	Policy reference	Page no.	Policy Summary
Stratford-on-Avon District Core Strategy	-	-	No policy.
Warwick District Local Plan	NE5	120	Developments expected to demonstrate that they do not sterilise mineral resources of particular importance unless extraction is not feasible prior to development taking place.

(64) Q-B7: Do you agree that it is appropriate to highlight links to the Minerals Plan, avoiding the unnecessary duplication of policy within the SWLP?

Issue B8: Agricultural Land

Land is a finite resource, and its role in food production is of high importance. It is recognised that national and international events may increase demand for UK-grown food in future, if importing food becomes more difficult or more expensive. Local food production has benefits in reducing carbon emissions from transportation, and community growing can have health and social benefits for those involved. Provision of allotments and community orchards is covered in section W4 – public open space for leisure and informal recreation.

In the face of national and global events and the climate emergency, farmers may be experiencing competing pressures. For example to maximise the productivity of their land, while at the same time moving to less carbon-intensive farming practices and increasing biodiversity through for example tree planting and through the growing demand for solar and wind farms. This is a complicated balance, the details of which are largely beyond the scope of the South Warwickshire Local Plan. However, from a climate change point of view these rural land uses have a key role to play in decarbonising our communities and economy and well as linking with adaptation. They also provide the opportunity for multiple benefits such as combining food production with solar production or tree planting.

Part 2 of the SWLP is expected to provide detailed policy to support the diversification of agriculture, while maintaining a balance regarding carbon emissions and enhancing soil health, biodiversity and enjoyment of the countryside.

Large scale development can use significant areas of land. Similar pressures can also arise from environmentally focused schemes such as solar farms and carbon off-setting. One key role the SWLP can play is ensuring that where possible the best agricultural land is retained in productive use.

Current adopted policy

Policy document	Policy reference	Page no.	Policy Summary
Stratford-on-Avon District Core Strategy	AS.10	192	Seek to avoid the loss of large areas of higher quality agricultural land
Warwick District Local Plan	NE5	120	Developments expected to demonstrate that they avoid the best and most versatile agricultural land unless the benefits of the proposal outweigh the need to protect the land for agricultural purposes.

(230) Q-B8.1: Do you agree that the plan should include a policy avoiding development on the best and most versatile agricultural land, unless it can be demonstrated that the harm to agricultural land is clearly outweighed by the benefit of development?

Q-B8.2: When considering climate change, biodiversity and economic wellbeing, are there any rural land uses or locations that should be prioritised over others?

Issue B9: Protecting Biodiversity and Geodiversity assets

South Warwickshire has a rich array of biodiversity and geodiversity assets. These are valued for their environmental, scientific, educational, historic, aesthetic and social benefit. Some of these sites are of national importance – Sites of Special Scientific Interest (SSSIs) – and as such are afforded statutory legal protection. Other sites are of local importance, and it falls to Local Plans to determine the appropriate level of protection.

Sites of local importance include:

Ancient Woodland, aged and veteran trees;
Local Nature Reserves;
Local Wildlife Sites and potential Local Wildlife Sites;
Local Geological Sites.
Protected, rare, endangered or priority species or other sites of geological or geomorphological importance.

South Warwickshire does not have any designated sites of international importance (Special Areas of Conservation, Special Protection Areas, or Ramsar sites).

Local Geological Sites are selected by a panel of representatives from Warwickshire Geological Conservation Group (WGCG), Natural England and Warwickshire Museum. The list is maintained by WGCG and forms part of the Geodiversity Action Plan.

Current adopted policy

Policy document

Policy reference

Page no.

Policy Summary

Stratford-on-Avon Core Strategy

CS.6

Developments with an adverse effect on a site designated through the EC Habitats Directive or Birds Directive will not be permitted.

Biodiversity – Proposals expected to minimise impacts on biodiversity and where possible secure net gain. Safeguarding is required of sites of national and local importance, and other non-designated sites known to make a positive contribution to biodiversity, unless the benefits of development clearly outweigh the harm. If harms cannot be mitigated onsite, offsetting is required elsewhere in the area.

Geodiversity – Proposals expected to safeguard Local Geological Sites and other features of geological interest, and where possible, conserve and enhance these features.

Warwick District Local Plan

NE2

118

Sites of national importance – Development not permitted which would destroy or adversely affect these unless, in exceptional circumstances, the benefits of the proposal clearly outweigh the need to protect the site.

Sites of local importance – Development not permitted which would destroy or adversely affect these unless the benefits of the proposal clearly outweigh the need to protect the site. Proposals are subject to an ecological assessment.

(271) Q-B9: Should the plan include a policy requiring the safeguarding of sites of national importance, sites of local importance, and other non-designated sites known to make a positive contribution to biodiversity or geodiversity; unless the benefits of the proposal clearly outweigh the need to protect the site. Where possible conserve and enhance these sites.

Q-B10: Please add any comments you wish to make about a biodiverse and environmentally resilient South Warwickshire

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