Object

Representation ID: 19924

Received: 01/04/2021

Respondent: Natural England

Natural England notes that the Interim Sustainability Appraisal (SA) Report provided in support of the Draft Local Plan is not intended, and is not able, to fully satisfy the requirements of a Strategic Environmental Assessment (SEA) Environmental Report at this stage of the plan-making process, and a that a further iteration will be undertaken following public consultation, which will take into account changes to the Draft Local Plan, as well as comments on the SA itself.

At this stage, Natural England advise that while Section 2.1.3 of the Interim SA Report sets out the key sustainability issues for consideration, we note that there are other sustainability issues that should be included, including amending the assessment criteria to include greater consideration of the protection of BMV agricultural land and soil resources from inappropriate development.

We also consider that there is scope for further consideration of opportunities that enhance ecological connectivity as part of the assessment criteria. There is a risk that in some situations, development on land of limited biodiversity value in its own right can lead to the creation of islands of biodiversity, permanently severed from other areas. We therefore suggest adding additional wording that captures the principle of ensuring that current ecological networks are not compromised, and future improvements in habitat connectivity are not prejudiced.

Notwithstanding the above, overall Natural England has concluded that a significant amount of further work is required to complete the SA for the Draft Local Plan, and on this basis, we will provide detailed comments once the finalised SA has been published for further consultation.