Comment

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

Representation ID: 23703

Received: 20/02/2017

Respondent: East Sussex County Council

Representation Summary:

Ecology

Reference should be made to Habitats and Species of Principal Importance and the policy should include protection of biodiversity outside designated sites.

In line with Defra guidance SNCIs are now referred to as Local Wildlife Sites (LWS). RIGGS are now referred to as Local Geological Sites (LGS).

ESCC should be added as a source of reference for LWS.

Where there are references to BAP habitats/species, text should include reference to Habitats and Species of Principal Importance.

Para 10.52-Ecological assessments/reports should be carried out in accordance with best practice guidance.

*Para 10.52-Ecological surveys and mitigation/compensation measures may be seasonally restricted.

Full text:

Ecology

-Biodiversity and green space

Broadly, yes, but reference should be made to Habitats and Species of Principal Importance under Section 41 of the NERC Act, and the policy should also allow for the protection of biodiversity (notable species and habitats) that occurs outside designated sites.

Additional comments:

* In line with Defra guidance, and to ensure consistency across Sussex, Sites of Nature Conservation Importance (SNCIs) should now be referred to as Local Wildlife Sites (LWS). Similarly, Regionally Important Geological and Geomorphological Sites (RIGGS) should now be referred to as Local Geological Sites (LGS).

* ESCC should be added as a source of reference for LWS (Table in para 10.50).

* Where the policy and accompanying text refers to BAP habitats and species, the text should include reference to Habitats and Species of Principal Importance as listed under Section 41 of the Natural Environment and Rural Communities (NERC) Act 2006 (which draws upon the UK BAP and therefore includes the same species).

* Para 10.52. Ecological assessments and reports carried out for developments should be carried out in accordance with best practice guidance (CIEEM Technical Guidance on Ecological Impact Assessments and Report Writing) and BS 42020:2013 Biodiversity - code of practice for planning and development.

* Para 10.52. It is important to note that ecological surveys and mitigation/compensation measures may be seasonally restricted. The time required to carry out appropriate mitigation/compensation prior to the commencement of development should also be programmed in.