Issue and Options 2023
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New searchIssue D1: Strategic design principles: There are a good range of topics included here however, environmental sustainability is a term broadly applied to a range of areas. However, a key building block includes the role that biodiversity plays within the sustainability of our natural world. Thus Natural England feels that it should be specifically mentioned as a separate but connected topic that acts as a golden thread.
Issue D2: Design Codes and design guides: Any design codes created in support of this plan would hugely benefit from adopting what could be described as its Golden Threads: Environmental growth and nature recovery. Environmental growth and nature recovery should go beyond the protection of a small proportion of our most important landscapes, biodiversity and protected sites. It should actively increase our environmental assets and make better use of nature for drainage, food growing and creating great places to be. All new development should help nature to recover, achieve biodiversity net gain and ensure that residents have access to good quality green and natural spaces and support integration. 1. Health and wellbeing: The environment should support achievement of better quality lifestyles through the places where we live, meet and play. With nature at their heart, the design of new layouts and communities should include active, connected and healthy places to live with opportunities to grow our own food and to walk or cycle to work and local facilities. 2. Inclusivity: All communities should benefit equally. New buildings and places must work for everyone, meaning that all ages and physical abilities are able to call Sth Warwickshire home and to be included in society. Developments that are comfortable, nature engaging and safe places for children will also be great places for adults. Equally, additional measures to help meet needs of those with limited movement, cognitive or sensory issues and our older community members will also help to make life easier for all residents. 3. Resilience to climate change: Our future living environment will be impacted and influenced by climate change. The natural and built environment are resilient to change and help to reduce our carbon footprint, both in terms of the operation of the building (including heating, lighting and ventilation) as well as the fabric of the building (considering low carbon materials, construction and transportation) and the way that we access buildings and places. We would encourage you to review the Cornwall County Council’s new Design Guide which takes a holistic approach and joins all these component options together. Cornwall Design Guide https://www.cornwall.gov.uk/media/vzkd4iaj/cornwall_design_guide_v2-0.pdf. Issue D5: Protecting and enhancing heritage assets: Protected landscapes: Natural England would like to see the character of protected landscapes conserved and enhanced (both direct and indirect pressures can impact on character). We want to ensure that proposed developments close to the boundaries of protected landscapes (within their settings) take proper account of their impacts on the Area of Outstanding Natural Beauty (AONB). The plan should encourage the enhancement of the Cotswold Area of Outstanding Natural Beauty, making reference to its Management Plan objectives. We recommend approaching the AONB’s planning lead to discuss how the plans can fit together. The plan should provide protected landscapes with the highest levels of policy protection for landscape and scenic beauty (including acknowledgement of wider purposes-landscape, natural beauty, understanding and enjoyment and cultural heritage) whilst having regard for their economic and social well-being. It should include appropriate policies to manage the nature, scale and location of development in the protected landscape, or, where appropriate, its setting. The plan should encourage the highest standards of design for such development.
Issue D4: Safe and attractive streets and public spaces: Natural England would like to see streets maximise opportunities for green infrastructure to create character and community use (where appropriate) and manage drainage and air quality. Appropriate planting and trees should be incorporated which reflect the context and climatic conditions/needs of the proposal. We would like to see innovative approaches that draw on Biophilic design attempts to achieve the benefits of contact between people and nature within the modern built environment. Recent studies have shown that experiencing nature on a daily basis supports people’s mental and physical health [7, 16,17,18,19] Table 1 below outlines the multiple benefits of biophilic design to the environmental, socio-psychological and economic aspects of urban life. 7 https://sustainableearthreviews.biomedcentral.com/articles/10.1186/s42055-020-00027-0#ref-CR7 16 https://sustainableearthreviews.biomedcentral.com/articles/10.1186/s42055-020-00027-0#ref-CR16 17 https://sustainableearthreviews.biomedcentral.com/articles/10.1186/s42055-020-00027-0#ref-CR17 18 https://sustainableearthreviews.biomedcentral.com/articles/10.1186/s42055-020-00027-0#ref-CR18 19 https://sustainableearthreviews.biomedcentral.com/articles/10.1186/s42055-020-00027-0#ref-CR19 Table 1 https://sustainableearthreviews.biomedcentral.com/articles/10.1186/s42055-020-00027-0#Tab1 Cities for Play: Designing streets that prioritise children over cars | Cities People Love [https://citiespeoplelove.co/article/cities-for-play-designing-streets-that-prioritise-children-over-cars]
Issue W1: Pollution: The plan currently considers air quality impacts on human health. But air quality is also significant threat to biodiversity. Many designated sites in Warwickshire receive damaging rates of air pollution, especially ammonia and nitrogen deposition. The plan should specifically address air quality impacts on designated sites. Commonly encountered air quality impacts to designated sites are associated with increased traffic resulting from housing development and industrial development, or from intensive agriculture proposals. The local plan HRA should assess the air quality impacts of increasing road traffic according to Natural England’s guidance document NEA001 (http://publications.naturalengland.org.uk/publication/4720542048845824). The plan should also consider the impacts of agricultural air pollution. It would be helpful if the plan could consider whether a Site Nitrogen Action Plan (SNAP) would be beneficial in alleviating some of the impacts - if indeed relevant to this next planning phase in Warwickshire. We encourage the Plan makers to keep abreast of and consider the ongoing developments that relate to Developing the UK Emissions Trading Scheme consultation and the Mission Zero Independent Review of Net Zerov- Review of Net Zero - GOV.UK (www.gov.uk) (https://www.gov.uk/government/publications/review-of-net-zero) Yes - we feel the Plan should begin to accommodate any policy development on Air Quality, for both human health and biodiversity, as early as possible in the plan making process. Issue W3: Ensuring the built environment provides healthy and inclusive communities: The plan should include a policy on light pollution to accommodate the needs of both nocturnal nature, astronomical night sky and peoples health and wellbeing. Light pollution - GOV.UK (www.gov.uk) In valuing the benefits of outdoor spaces, the Outdoor Recreation Valuation Tool (ORVal) is a web application developed by the Land, Environment, Economics and Policy (LEEP) Institute at the University of Exeter with support from DEFRA. ORVal’s primary purpose is to help quantify the benefits that are derived from accessible outdoor recreation areas in England. Those outdoor recreation areas, or greenspaces, include an array of features such as beaches, parks, nature reserves and country paths. ORVal Outdoor Recreation Valuation (exeter.ac.uk) (https://www.leep.exeter.ac.uk/orval/) Issue W4: Public Open Space for leisure and informal recreation: NE support the ethos behind this policy. In support of this you will find NE’s recently launched Green Infrastructure Framework (GIF) guidelines of use in helping design spaces. Natural England unveils new Green Infrastructure Framework - GOV.UK (www.gov.uk) https://www.gov.uk/government/news/natural-england-unveils-new-green-infrastructure-framework The standards for Accessible Natural Greenspace standards in Towns (ANGSt) have been updated and included within the new GI framework. Large data surveys carried out by NE will be very useful in informing this policies ongoing development. The People and Nature Survey (PANS) for England gathers evidence and trend data through an online survey relating to people’s enjoyment, access, understanding of and attitudes to the natural environment, and it’s contributions to wellbeing. It began collecting data in April 2020 and has been collecting data since. So far, data is published that was collected between April 2020 and March 2022 – the survey is ongoing. The People and Nature Survey - GOV.UK (www.gov.uk) Natural England’s - Monitor of Engagement with the Natural Environment (MENE): The MENE survey provided trend data for how people experience the natural environment in England – 2014 to 2022. Tranquillity is an important landscape attribute in certain areas e.g., within National Parks/AONBs. Local Planning Authorities should consider whether there are any such areas of tranquillity in their areas, and map (or otherwise spatially identify) them and provide appropriate policy protection. The only currently available national data source on tranquillity is held by CPRE here: Tranquillity Map: England - CPRE. https://www.cpre.org.uk/resources/tranquility-map-england/ Green infrastructure: A network of multi-functional green and blue spaces and other natural features, urban and rural, which is capable of delivering a wide range of environmental, economic, health and wellbeing benefits for nature, climate, local and wider communities and prosperity. There should be a strategic approach to Green Infrastructure (GI) provision and the plan should set out a clear strategy for its delivery. This could include GI targets, standards, requirements for development and opportunity areas. The strategy may be based on current GI strategies, upcoming GI strategies, other natural environment strategies or biodiversity opportunity/ecological network mapping. The plan should identify deficiencies in GI provision and opportunities for new GI. The GI policy should support and align with other natural environment and active travel policies (e.g., BNG investment can support wider GI outcomes). Green Infrastructure policy needs to ensure that health and wellbeing outcomes are being maximised for all. The policy should address unequal access to natural green space and the needs of different user, age, and socio-economic groups. See also section 7.4 of this letter. Refer to PPG on GI here: Natural environment - GOV.UK (www.gov.uk). https://www.gov.uk/guidance/natural-environment#green-infrastructure Green Infrastructure standards and guidance, currently under development should be embedded in future local plans once finalised.
Issue T4: Smart Cities: Here are two examples of good practice to aspire to. Singapore known for its City of Nature and Smart Technologies – combines the two. It is very cutting edge in its approach to creating futuristic cities that mix both Smart technologies alongside Green Policies. Their Green Plan (1930) is a sustainable development agenda, with firm action plans, touching on almost every dimension of peoples lives in the city. Our Vision (greenplan.gov.sg) https://www.greenplan.gov.sg/vision Soule (South Korea) offers a good example of a leading innovator in this area. They are using specific location-based open data. This data use offers sustainable solutions to address the problems of an ageing population, urban migration and climate change, to deliver solutions which will have a positive economic impact - The Top 10 Smart Cities In Asia (Updated 2021) (beesmart.city) https://www.beesmart.city/en/strategy/top-10-smart-cities-in-asia
Issue T1: 20-minute neighbourhoods: NE fully supports the Plan in encouraging developers to follow the principles outlined in the 20 minute neighbourhood guidance (source: TCPA). In support of this you will find NE’s recently launched Green Infrastructure Framework (GIF) guidelines of use in helping design spaces. GIF provides a structure to analyse where greenspace in urban environments is needed most. It aims to support equitable access to greenspace across the country, with an overarching target for everyone being able to reach good quality greenspace in their local area. Natural England unveils new Green Infrastructure Framework - GOV.UK (www.gov.uk) https://www.gov.uk/government/news/natural-england-unveils-new-green-infrastructure-framework
Issue B3: Special landscape areas: NE supports the concept of Special Natural Landscape Areas as applied to Stratford Upon Avon considered as an approach. We encourage you to be aware of the following NE documentation - An approach to landscape sensitivity (publishing.service.gov.uk). https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/817928/landscape-sensitivity-assessment-2019.pdf We encourage the Plan to consider and be sensitive to the needs of any biodiversity, geodiversity sites within the area and to also ensure that other proximal non-designated sites for nature conservation (Tier 2 - e.g. Special Wildlife Sites etc.. ) are also recognised as important and potential stepping stones for biodiversity thus enabling migration between designated sites – as per the Lawton Principles (‘Making space for nature’: a review of England's wildlife sites published today - GOV.UK (www.gov.uk)). https://www.gov.uk/government/news/making-space-for-nature-a-review-of-englands-wildlife-sites-published-today Issue B4: Protecting the Cotswold Area of Outstanding Natural Beauty (AONB) and its surrounding areas: The plan should refer to the major developments tests and define what the LPA consider to be major development. The major development test is NPPF paragraph 177 and it sets out the circumstances under which major development can be exceptionally permitted within an AONB. Issue B5: Environmental Net Gain: We support your use of Environmental Net Gain (Water, Air, Biodiversity, Carbon) however be aware of the Environment Act’s mandate towards Biodiversity Net Gain (BNG) at a minimum of 10% over a 30 year agreement. Some Local Authorities have chosen to set higher BNG requirements (e.g. 20% over 30+ years). However, any increased targets within policy must be evidenced (in terms of viability). Allocations within the local plan area should have (as a minimum) survey data showing biodiversity baseline & indicate whether BNG to be on or off site. It is preferrable to insist that BNG is first and foremost carried out on site (or as close to where appropriate) in order to benefit the local communities connected to the site area. Strategic significance for nature should be established through LNRS/other biodiversity strategy and articulated (given weight) in plan policy. For more information please review - Biodiversity net gain - GOV.UK (www.gov.uk) https://www.gov.uk/government/collections/biodiversity-net-gain Issue B6: Wildbelt designations: NE is enthusiastic and supportive of the Plan using this concept in that it not only fits with the pending Local Nature Recover Strategies, Biodiversity Net Gain and Green Infrastructure Framework in addition to reinforcing the Lawton Principles. The Wildbelt will help connect and protect any wider protected statutory designated sites within the area. They also offer alternative places for informal recreation in providing wild places/experiences for local people close to home. We encourage appropriate managed people access were possible in order to enhance peoples wellbeing experiences. Issue B8: Agricultural Land: The plan should have a policy for the protection of Best and Most Versatile (BMV) agricultural land or refer to the NPPF policy (i.e Best and Most Versatile (BMV) agricultural land: Land in grades 1, 2 and 3a of the Agricultural Land Classification). Areas of poorer quality land (ALC grades 3b, 4, 5) should be preferred to areas of higher quality land (grades 1, 2 and 3a). The plan should recognise that development has an irreversible adverse impact on the finite national and local stock of BMV land. Avoiding loss of BMV land is the priority as mitigation is rarely possible. Retaining higher quality land enhances future options for sustainable food production and helps secure other important ecosystem services. In the longer term, protection of BMV land may also reduce pressure for intensification of other land. Any development should have a soil handling plan and sustainable soil management strategy based on detailed soils surveys. Issue B9: Protecting Biodiversity and Geodiversity assets: Designated sites must be protected from the impacts of development. Designated sites should be mapped. Designated sites and specific impact pathways can be identified via our Impact Risk Zones on Magic. https://magic.defra.gov.uk/ The Plan must have criteria-based policies to guide decisions on developments that could impact designated sites. For example, the plan policy could set out certain development restrictions within a certain buffer from a designated site. The plan should distinguish between international, national and local sites. It should identify and include policies to protect and enhance local wildlife sites and geological sites (which can have local site or SSSI status). The plan should make it clear how specific impacts from new development will be addressed, e.g. recreational disturbance from new housing. The plan should promote the protection and recovery of priority species and habitats. For information, Habitats and species of principal importance in England (http://jncc.defra.gov.uk/page-5705) lists priority species and habitats (i.e. those material to planning). Reference should also be made to the Natural Environment PPG (https://www.gov.uk/guidance/natural-environment). The plan should make explicit reference to geological conservation and the need to conserve, interpret, and manage geological sites and features in the wider environment in order to provide ongoing educational inspiration and learning. The plan should include a policy to protect ancient woodland and ancient or veteran trees or other irreplaceable habitats. Ancient woodland is defined as an area that has been wooded continuously since at least 1600 AD. It includes ancient semi-natural woodland and plantations on ancient woodland sites (PAWS). For more information see Ancient woodland and veteran trees: protecting them from development (https://www.gov.uk/guidance/ancient-woodland-and-veteran-trees-protection-surveys-licences). Priority habitats, ecological networks and priority and/or legally protected species populations The Local Plan should be underpinned by up to date environmental evidence. This should include an assessment of existing and potential components of local ecological networks. This assessment should inform the Sustainability Appraisal, ensure that land of least environment value is chosen for development, and that the mitigation hierarchy is followed and inform opportunities for enhancement as well as development requirements for particular sites. Priority habitats and species are those listed under Section 41 of the Natural Environment and Rural Communities Act, 2006 and UK Biodiversity Action Plan (UK BAP). Further information is available here: [ARCHIVED CONTENT] Natural England - Habitats and species of principal importance in England (nationalarchives.gov.uk). https://webarchive.nationalarchives.gov.uk/ukgwa/20140712055944/http:/www.naturalengland.org.uk/ourwork/conservation/biodiversity/protectandmanage/habsandspeciesimportance.aspx Biodiversity Action Plans (LBAPs) identify the local action needed to deliver UK targets for habitats and species. They also identify targets for other habitats and species of local importance and can provide a useful blueprint for biodiversity enhancement in any particular area. Protected species are those species protected under domestic or European law. Further information can be found here -Protected species and development: advice for local planning authorities - GOV.UK (www.gov.uk) Sites containing watercourses, old buildings, significant hedgerows and substantial trees are possible habitats for protected species. Ecological networks are coherent systems of natural habitats organised across whole landscapes so as to maintain ecological functions. A key principle is to maintain connectivity - to enable free movement and dispersal of wildlife e.g. badger routes, river corridors for the migration of fish and staging posts for migratory birds. Local ecological networks will form a key part of the wider Nature Recovery Network proposed in the 25 Year Environment Plan. Where development is proposed, opportunities should be explored to contribute to the enhancement of ecological networks. Planning positively for ecological networks will also contribute towards a strategic approach for the creation, protection, enhancement and management of green infrastructure, as identified in paragraph 171 of the NPPF. Page 4 of 6 Where a plan area contains irreplaceable habitats, such as ancient woodland, ancient and veteran trees, there should be appropriate policies to ensure their protection. Natural England and the Forestry Commission have produced standing advice on ancient woodland, ancient and veteran trees - Ancient woodland, ancient trees and veteran trees: advice for making planning decisions - GOV.UK (www.gov.uk) https://www.gov.uk/guidance/ancient-woodland-ancient-trees-and-veteran-trees-advice-for-making-planning-decisions
