Object

Representation ID: 19837

Received: 01/04/2021

Respondent: Natural England

We advise that wording of both points 3 and 4 could be made more robust through the following amendments which emphasise the role of the natural environment in delivering measures to reduce the effects of climate change through nature-based solutions (for example tree planting to moderate heat island effects), and the importance of restoring natural assets where possible:

3. Incorporating green infrastructure into the scheme from the outset, including such measures as the provision of: areas of green space and green corridors, landscaping, tree planting and retention of existing trees and hedgerows, and nature-based solutions such as green roofs and walls, and SuDS (Policy SP10).

4. Facilitating the management, restoration, enhancement and expansion, of vulnerable habitat types: primarily blanket bog and woodland, which are important for carbon sequestration; and ensuring a net gain in biodiversity (Policy EN2).

Specific reference to net gain is also made within policies SP9, SP10 and TR2, however, the minimum 10% net gain is only stated in TR2. For the sake of consistency it is recommended that these policies either state the 10% minimum net gain requirement or make specific reference to Policy EN2.