Object

Representation ID: 19872

Received: 01/04/2021

Respondent: Natural England

Overall, Natural England consider the scope of the pollutants considered within Policy EN9 to be adequate but advise that the wording of this policy could be strengthened by including:

- policy requirement for development to provide a robust evidence base and field surveys where necessary, to establish the status of agriculture land that could be Best and Most Versatile
- Further emphasis on the importance of soil as a finite resource
- Recognition that soils of high environmental value (e.g. wetland and carbon stores such as peatland) should also be considered as part of ecological connectivity. This should also be reflected within Policy EN2: Biodiversity and Geodiversity

The Draft Local Plan policies should also refer to the Defra Construction Code of Practice for the Sustainable Use of Soils on Construction Sites. It is important to recognise that development (soil sealing) has an irreversible adverse (cumulative) impact on the finite national and local stock of BMV land. Avoiding loss of BMV land is 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.

Natural England also advise that Policy EN9 could be made more robust by including further consideration of the impacts of light pollution. Light pollution has negative impacts on local amenity, intrinsically dark landscapes and nature conservation (especially bats and invertebrates). The Draft Local Plan should address the impacts of light pollution on the natural environment through Policy EN9 and other policies as appropriate (e.g. design policies). Light pollution mapping is available from CPRE.