Regulation 18 Draft Local Plan

Object

Representation ID: 2128

Received: 24/04/2024

Respondent: Greater Lincolnshire Nature Partnership, Natural England and Lincolnshire Wildlife Trust

The inclusion of climate change within the vision is welcome. However, it is felt that while there is reference to protecting and enhancing the natural environment, specific mention of nature recovery and the Nature Recovery Network would strengthen the plan’s commitment to the nature and biodiversity. It is felt that this, on top of the commitment to protect and enhance the natural environment, would contribute to the positive preparation of the plan, as required by paragraph 15 of the NPPF. Especially in relation to the environmental objective of sustainable development (NPPF paragraph 8c).

Support

Representation ID: 2129

Received: 24/04/2024

Respondent: Greater Lincolnshire Nature Partnership, Natural England and Lincolnshire Wildlife Trust

The strategic objectives are generally welcomed, particularly Objective 13.
While the inclusion of Objective 12 is supported, given the intention to amend the objectives in accordance with strengthened national policy on biodiversity net gain, as stated in the summary of proposed changes, it might be useful to include reference to biodiversity net gain within the text.
By only referring to biodiversity net gain in Objective 13, which is focused on climate change, its role in nature recovery and addressing the biodiversity crisis may be undermined.

Support

Representation ID: 2130

Received: 24/04/2024

Respondent: Greater Lincolnshire Nature Partnership, Natural England and Lincolnshire Wildlife Trust

Once prepared, any climate change policy within the Regulation 19 draft should include the role of nature in addressing climate change and its impacts, through nature-based solutions, including landscape scale projects, and green infrastructure. This would contribute to the environmental objective of sustainable development as laid out in paragraph 8c of the NPPF as well as other paragraphs including 20d, 102, and 159a.

Support

Representation ID: 2131

Received: 24/04/2024

Respondent: Greater Lincolnshire Nature Partnership, Natural England and Lincolnshire Wildlife Trust

The inclusion of this policy is welcome.

Support

Representation ID: 2132

Received: 24/04/2024

Respondent: Greater Lincolnshire Nature Partnership, Natural England and Lincolnshire Wildlife Trust

This policy is generally welcome.

Object

Representation ID: 2133

Received: 24/04/2024

Respondent: Greater Lincolnshire Nature Partnership, Natural England and Lincolnshire Wildlife Trust

To bring paragraph 10.4 in line with the associated paragraph in the NPPF (180), either bullet point one should include “biodiversity sites of value” or bullet point three should include reference to enhancing biodiversity.
in light of mandatory biodiversity net gain, which requires there to be a net gain in biodiversity, and the biodiversity duty (NERC Act, 2006), it is felt that “where possible” should be replaced with “where appropriate”. This removes to potential for ‘net gains in’ and ‘enhancement of’ biodiversity to not be achieved while acknowledging that there are wider challenges to achieving them.
Suggests wording changes to bullet point 3.
Reference to the Local Nature Recovery Strategy is welcome in Paragraph 10.8, however it is felt that further explanation is required.

Support

Representation ID: 2134

Received: 24/04/2024

Respondent: Greater Lincolnshire Nature Partnership, Natural England and Lincolnshire Wildlife Trust

This policy is broadly supported. Again, further explanation of the LNRS should be included in supporting paragraphs.

Object

Representation ID: 2135

Received: 24/04/2024

Respondent: Greater Lincolnshire Nature Partnership, Natural England and Lincolnshire Wildlife Trust

The inclusion of this policy is welcome. In light of secondary legislation and recently published guidance (https://www.gov.uk/guidance/biodiversity-net-gain) some amendments are required.
The inclusion of paragraph 10.9 is supported, but it is felt that it needs to be updated following the commencement of mandatory biodiversity net gain. The paragraph should include the date from which the biodiversity net gain condition came into effect for major development and small sites.
The inclusion of paragraph 10.11 is supported, but suggests adding ‘it also identifies opportunities to enhance this network’ after “These maps identify known areas of high biodiversity value which make up the core of the District’s wider ecological network” for clarification.
Paragraph 10.3 should make it clear that Biodiversity Opportunity and Green Infrastructure Mapping will be used to assign strategic significance in relation to biodiversity net gain, within the Statutory Biodiversity Metric. It should also make it clear that Biodiversity Opportunity Mapping will be incorporated within the LNRS.
While reference to the LNRS is welcome, it is again felt that further information should be included.

Object

Representation ID: 2136

Received: 24/04/2024

Respondent: Greater Lincolnshire Nature Partnership, Natural England and Lincolnshire Wildlife Trust

The inclusion of this policy is supported, though it is felt it could be expanded to more reflect advice included in Natural England’s Green Infrastructure Framework: Principles & Standards. Applying these standards locally can help to deliver good green infrastructure networks which provide multiple benefits.
Including standards on green infrastructure such as Accessible Greenspace, Urban Nature Recovery, Urban Greening Factor, Urban Tree Canopy Cover, as well as strategic Sustainable Urban Drainage (SuDS), within the Local Plan, will offer developers greater certainty about what green infrastructure is required on site when used in conjunction with the Green Infrastructure Mapping developed by the GLNP and Green Infrastructure Principles in Appendix 2.
It is also felt that to help the GI standards to be delivered, local authorities should set green infrastructure targets. These should include delivery levels over time. For instance, the % of people having good quality publicly accessible greenspaces within 15 minutes’ walk from home by 2030.
It is also suggested that the health benefits of green infrastructure should be emphasised.
In relation to access to nature Natural England’s Accessible Greenspace Standard (GI Standard 2) should be used. This I in line with the Environment Improvement Plan (EIP) Goal 10: Enhancing beauty, heritage and engagement with the natural environment.

Object

Representation ID: 2137

Received: 24/04/2024

Respondent: Greater Lincolnshire Nature Partnership, Natural England and Lincolnshire Wildlife Trust

It is felt that paragraph 4 of this policy should state that SUDS should be designed in accordance with Schedule 3 of the Flood and Water Management Act and any other relevant legislation.
The policy should also refer to the role of nature-based solutions in flood management at a wider catchment scale. Promoting their use where appropriate and feasible.