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Representations on BMSDC Joint Local Plan Consultation Document (Interactive) - Biodiversity

Representation ID: 13039

COMMENT Sproughton Parish Council (Mrs Susan Frankis)

Summary:

Q51-54

Option BIO2 appears, with some reservations, to be the better option.
We would recommend much more robust and critical assessment of SUDS on new developments feeding into river valleys and Flood plains.
Option BIO2 appears, with some reservations, to be the better option.
Visual impact is a big consideration.
When considering the new build of larger groups of houses and other buildings there are many benefits from collective energy (power and heat) schemes.

See full rep attached.

More details about Rep ID: 13039

Representation ID: 13027

COMMENT Ipswich Borough Council (

Summary:

The proposal to require an impact assessment for all edge of centre and out of centre retail proposals that are 400 square metres gross floorspace or more is different from that currently required in Ipswich of 200 square metres net or more. A common approach developed through all the Local Plans in the IFEA would be supported.

More details about Rep ID: 13027

Representation ID: 12968

COMMENT Dr Jonathan Tuppen

Summary:

One of the problems with most wildlife legislation in relation to development is the references to 'public advantages outweighing any adverse biodiversity impact'.
The guidance is subjective and the responsibility to enforce/ police these regulations is devolved by Natural England to the local planning authority.
It is the LA's decision as to how closely the developer has to look for biodiversity in the first place, so if you don't look you don't find. They are therefore, benefactor, regulator, enforcer, judge and jury which we believe puts their officers in a difficult position i.e. there is a conflict of interest

More details about Rep ID: 12968

Representation ID: 12533

COMMENT Place Services at Essex County Council (Mr Hamish Jackson)

Summary:

Para3: Weston Fen mentioned - is not within Mid Suffolk, but within St Edmundsbury Borough instead.
Para4: Should also include reference to RAMSAR sites as equivalent to N2k sites; use UK Habitat Regulations rather than Habitats Directive to provide post-Brexit security measures.
Para6: There should be reference to following: NERC act 2006 biodiversity duties for public bodies; England Biodiversity Strategy 2020; Net Gain initiative and promote the use of DEFRA's biodiversity metric calculator.
Para7: Local Nature Reserves should also be referenced.
Para10: If MSDC signs up to the Suffolk RAMS then paragraph will need amending.

More details about Rep ID: 12533

Representation ID: 11247

OBJECT Suffolk Wildlife Trust (Mr James Meyer)

Summary:

The Local Plan must protect and enhance the natural environment and must be based on up to date evidence. The emerging RAMS should be extended to cover the relevant parts of Mid Suffolk district.

More details about Rep ID: 11247

Representation ID: 10998

COMMENT Babergh Alliance of Parish & Town Councils (Helen Davies)

Summary:

JLP makes reference to areas that are legally protected for their biodiversity. Here we see the first references to exceptions due to public interest. One of the problems with most wildlife legislation in relation to development is the references to 'public advantages outweighing any adverse biodiversity impact'. Problem with such guidance is it is subjective and the responsibility to enforce is devolved to the local planning authority. It is the LA's decision as to how closely the developer has to look for biodiversity in the first place, if you don't look you don't find - conflict of interest.

More details about Rep ID: 10998

Representation ID: 8271

OBJECT Ms Helen Davies

Summary:

In this section there is a reference to areas that are legally protected for their biodiversity BUT also an exception for development when in the public interest. Obviously this leads to a conflict of interest for the district council who would like the new homes bonus and council tax versus retaining protected land. How will this be managed in a clear open honest and transparent way??
Sproughton's Chantry Vale is a Special Landscape Area however this is seemingly overridden by BDC and Taylor Wimpey - witness Wolsey Grange and the additional adjoining sites proposed.

More details about Rep ID: 8271

Representation ID: 8127

COMMENT Mr Peter Powell

Summary:

This needs to be more transparent with direction from a third party. Preferably a public interest organisation like Suffolk Wildlife from the earliest stage of a project.

More details about Rep ID: 8127

Representation ID: 8080

OBJECT RSPB Stour Estuary and Wolves Wood (Mr Mark Nowers)

Summary:

A competent authority may only derogate from Regulation 61 where there is an absence of alternative solutions, and it is satisfied that there are imperative reasons of public interest that override the protection of the European Site(s) and that compensatory measures have been secured that protect the overall coherence of the Natura 2000 network (Regulations 62 and 66). If there are less damaging alternative solutions, no derogation is permitted and consent must be refused.

More details about Rep ID: 8080

Representation ID: 6809

COMMENT Mr Grenville Clarke

Summary:

I would ask that hedgerows receive the same protective status as Ancient SSSI woodlands and listed buildings. They deserve proper protection and Officers to ensure that education and maintenance of the hedgerows is enhanced.

Where is the avoidance and Mitigation Strategy (2017) to be found.

More details about Rep ID: 6809

Representation ID: 6781

COMMENT Mr Grenville Clarke

Summary:

There is no mention of the value of Hedgerows. The Suffolk Hedgerow survey was undertaken between 1998 and 2012, with all District Councils involved. Over 40,000 hedgerows were surveyed and crucial data on their structure and landscape value were revealed. I am therefore unable to determine what your view is regarding these vital habitats. Many of the hedgerows are over 500 years' old and some as old as 1000 years old. They are vital in linking other habitats to one another and are the subject of research into their contribution to conservation and biodiversity.

More details about Rep ID: 6781

Representation ID: 6574

SUPPORT MSDC Green Group (Cllr John Matthissen)

Summary:

See strengthened Environmental Issues section above, especially unprecedented extinction event.
The strategic priority is to protect and enhance, especially in creating corridors and linkage between and outside areas with designations.
Evidence should include the tree cover survey of Suffolk, and regular monitoring.
Policy is needed to ensure tree planting on an increasing scale, for landscape, climate change and health reasons, as well as strengthening biodiversity.

More details about Rep ID: 6574

Representation ID: 3293

OBJECT Drinkstone Parish Council (Mrs Daphne Youngs)

Summary:

The document fails to properly address the key environmental issues facing the two districts. The options for comment provide limited environmental protection policies or "do nothing." The Suffolk Nature Strategy is referred to as Key Evidence but there are no proposals for taking forward its recommendations. Mid Suffolk needs to produce a green infrastructure strategy as a matter of urgency. The emerging Habitats Regulation Assessment Disturbance and Avoidance and Mitigation Strategy being produced by Babergh and others needs to cover Mid Suffolk too. Green infrastructure is all sport/play focussed and does not consider a wildlife enhancement role.

More details about Rep ID: 3293

Representation ID: 895

OBJECT Mr. Nick Miller for Sudbury Green Belt Group

Summary:

Much more weight is given to the economic than social or environmental . All three topics are referred to in the context of building development; and the environmental safeguards referred to are the statutory minimum. Even balance requires a new 'open space assessment' of all town areas and town fringes, so the building is fitted round the green spaces, not vice versa. Otherwise most townspeople seeking open space or to explore biodiversity, will need to get there by car, as green space and countryside will no longer be within day-to-day walking distance of the populous areas, certainly round Sudbury.

More details about Rep ID: 895

Representation ID: 782

OBJECT Supporters Against Fressingfield Expansion (SAFE) (Dr John Castro)

Summary:

The plan talks about only safeguarding natural habitats in Special Protection areas and Special Areas of Conservation! These are tiny pockets within the open countryside in the District and as national planning policy advises, their habitats should be protected by making sure they are connected and undisturbed by development.

The same protection for Landscape is only given to areas of designation in the local plan which is again selective and wrong. We would argue that protection should be given to areas of rural landscape. Economic policy is wrongly put at the top of the agenda in the Draft Local Plan at the cost of our own unique rural county.

More details about Rep ID: 782

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