Comment

Development and Site Allocations (DaSA) Local Plan - Options and Preferred Options

Representation ID: 23175

Received: 19/02/2017

Respondent: Rother Environmental Group

Representation Summary:

A positive approach to biodiversity is welcomed but the policy needs revising:

*(ii)-the aim should be to prevent a net loss of biodiversity.
*Wording of(iii) should be strengthened "...all developments must retain and enhance biodiversity...".
*To ensure that a comprehensive network of habitats is maintained.
*To contribute to the protection, management and enhancement of biodiversity.
*To make a positive contribution to biodiversity, through the restoration/enhancement.
*To maintain existing green spaces and provide alternative equivalent where appropriate.
*Proposals which have an adverse impact on bio/geodiversity or green spaces, which cannot be adequately avoided, mitigated or compensated for, will be refused.

Full text:

Policy DEN4:
A positive approach to biodiversity is welcomed. However, we feel that the policy needs to be revised:
* In (ii) the aim should be to prevent a net loss of biodiversity, not 'avoid significant
harm'.
* The wording of sub-section (iii) strengthened from "...all developments will be
expected to retain and enhance biodiversity..." to "...all developments must retain
and enhance biodiversity...".
* To ensure that a comprehensive network of habitats is maintained. To help this
aim, sub-section (iv) should seek that Green Infrastructure (GI) strategies for
individual developments link into the GI strategy for the district.
* To contribute to the protection, management and enhancement of biodiversity.
* To make a positive contribution to biodiversity, through the restoration and
enhancement of existing habitats, as well as the creation of new ones.
* To maintain existing green spaces and provide alternative equivalent where
appropriate.
* Proposals which have an adverse impact on bio or geodiversity or green spaces,
which cannot be adequately avoided, mitigated or compensated for, will be
refused.

It would also be appropriate to cross reference the policy to the Green Infrastructure
background paper and the need for all developments to undertake biodiversity
surveys if they meet the criteria set out. Currently a lot of smaller developments do
not submit surveys in the first instance and rely on the planning officers to pick this
up. The Council's Validation Checklists should be reviewed to ensure that this is
picked up at validation rather than later when the 'clock is ticking'.

Access to the Countryside and green spaces need to be protected.