Local Plan Review: Preferred Approach 2016-2035

Object

Representation ID: 2810

Received: 07/02/2019

Respondent: Sussex Wildlife Trust

The supporting text to this policy does not highlight that buildings in the countryside may be valuable for biodiversity. SWT feel that this should not be overlooked as changes to use or reuse may impact that biodiversity. This matter is also not addressed in the policy wording, therefore we propose the wording in the form of an additional bullet point

Object

Representation ID: 2812

Received: 07/02/2019

Respondent: Sussex Wildlife Trust

The supporting text to this policy does not acknowledge biodiversity value of the wider countryside. SWT feel that this should not be overlooked as building in the countryside outside the settlement boundaries may significantly impact biodiversity. This matter is also not addressed in the policy wording and suggest wording in the form of an additional bullet point

Support

Representation ID: 2814

Received: 07/02/2019

Respondent: Sussex Wildlife Trust

We support the inclusion of a lighting policy and welcome the acknowledgement in section 7.142 that wildlife can be impacted by lighting schemes. However we do not feel that this is clearly translated into policy and as a result it may not be effective. The NPPF clear states in paragraph 180c planning policies and decisions should 'limit the impact of light pollution from artificial light on local amenity, intrinsically dark landscapes and nature conservation'. Therefore we propose amendments to policy DM23 bullet point 3:

Comment

Representation ID: 2816

Received: 07/02/2019

Respondent: Sussex Wildlife Trust

SWT notes that in section 7.169 of the supporting text the mitigation hierarchy is mentioned, although not explicitly referenced. Our concern is that although the text mentions mitigation and compensation, the need to first avoid impacts through location and/or design of development is not clearly set out. We remind CDC that the first step in the mitigation hierarchy is to avoid. We therefore proposed that this is made clear in the supporting text through amendments to section 7.169

Support

Representation ID: 2818

Received: 07/02/2019

Respondent: Sussex Wildlife Trust

The Sussex Wildlife Trust is supportive of Local Plans having policies in place to protect, conserve and enhance and deliver net gains to biodiversity. Therefore we welcome CDC continued commitment to biodiversity through the inclusion of this policy.
We support CDC's statement in section (7.172) which recognises that conserving biodiversity must not be limited to protected/designated sites. We are proposing that the term prevent in this section is changed to avoid in order to align better with the mitigation hierarchy as per the NPPF

Comment

Representation ID: 2819

Received: 07/02/2019

Respondent: Sussex Wildlife Trust

We would like to highlight a matter relating to the text within the policy. The text refers to bullet points a and b however the bullet points are numbered not letter and therefore this needs amending, this error occurs twice in the policy.

Support

Representation ID: 2824

Received: 07/02/2019

Respondent: Sussex Wildlife Trust

Support the policy and welcome the wording in bullet point 4, which highlights the need for a buffer in relation to ancient woodland and ancient/veteran trees. Bullet point would benefit from stating the need to also avoid impacts on Ancient Woodland and Ancient/veteran trees as per paragraph 175 of the NPPF and Natural England's ancient woodland standing advice.

Support

Representation ID: 2826

Received: 07/02/2019

Respondent: Sussex Wildlife Trust

SWT supports the inclusion of a policy to enshrine the importance of green infrastructure in the CDC Local Plan. Having looked at the supporting text we note that reference is made to the GI checklist from the Delivering Green Infrastructure Local Plan Area document (2016). Although this document was a step down from the promised SPD, we hope the document has offered valuable guidance to developers. We recommend to CDC that reference to the Checklist is made within the policy, so developers are aware of it and the benefits of using it.

Recommend the policy wording is made more ambitious.

Support

Representation ID: 2828

Received: 07/02/2019

Respondent: Sussex Wildlife Trust

We welcome bullet point three within this policy, which recognises the importance the afore mentioned assets may provide for biodiversity and within the green infrastructure network.

Comment

Representation ID: 2829

Received: 07/02/2019

Respondent: Sussex Wildlife Trust

Due to the often rural nature of Equestrian Development, we propose an amendment to bullet point 4 of the policy to ensure potential impacts to biodiversity are captured