Chapter 19
179) Do you agree that the proposed approach to planning for the natural environment in policy N1, including the proposed approach to biodiversity net gain, strikes the right balance between consistency, viability, deliverability, and supporting nature recovery? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Neither agree nor disagree.
a) Please provide your reasons, particularly if you disagree.
The RTPI welcomes the inclusion of reference to Local Nature Recovery Strategies. We understand that this policy has been amended to limit the circumstances in which plans may seek biodiversity net gain (BNG) contributions which exceed the statutory requirement. The RTPI considers that any increase above the national threshold should be robustly viability checked to ensure that other national requirements, such as affordable housing, can still be delivered. This is especially relevant given the approach to exemptions from biodiversity net gain (BNG) contributions set out within footnote 69.
180) In what circumstances would it be reasonable to seek more than 10% biodiversity net gain on sites being allocated in the development plan, especially where this could support meeting biodiversity net gain obligations on other neighbouring sites in a particular area?
The RTPI believes an increased amount of BNG above 10% would need to be evidenced including the local need for a higher percentage, local opportunities for a higher percentage and any impacts on viability for development.
181) Do you agree policy N2 sets sufficiently clear expectations for how development proposals should consider and enhance the existing natural characteristics of sites proposed for development? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Neither agree nor disagree.
a) Please provide your reasons, particularly if you disagree.
The wording of N2(1f) is very vague and the inclusion of the phrase ‘priority or threatened species’ opens up a requirement to include features for 940 different species. This should be amended to refer to species identified in the Local Nature Recovery Strategy or a site-specific ecological survey as being a priority to protect and recover for the area of the development site.
We note some concern over the sequential test to development on prime agricultural land being introduced to decision making in N2(1)(b). Given the resource intensive nature of such proposal the RTPI would support the reinstatement of such an approach through development planning in N1 instead. We note the lack of question relating to N3, but if street trees are to be better included in new developments, such proposals will need clear reference in Chapter 14, and the Design and Placemaking PPG.
182) Do you agree the policy in Policy N4 provides a sufficiently clear basis for considering development proposals affecting protected landscapes and reflecting the statutory duties which apply to them? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Neither agree nor disagree.
a) Please provide your reasons, including how policy can be improved to ensure compliance.
The RTPI is concerned that, as drafted alongside presumptions set out in S3 to S5, there may be a weakening of protections currently given to protected landscapes, especially in relation to major development. A careful balance needs to be struck between driving economic growth whilst protecting and enhancing our nationally designated landscapes, particularly when considering our need to meet environmental targets.
183) Do you agree policy N6 provides clarity on the treatment of internationally, nationally and locally recognised site within the planning system? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Partly agree.
a) Please provide your reasons, particularly if you disagree.
The RTPI notes that N6(1)(a)(ii) and N6(1)(b)(iii) currently direct all compensation measures towards EDPs. This runs contrary to the Habitat Regulations and will cause issues during the transition period as EDPs begin to emerge.
The definition of Ancient or veteran trees should also be reinstated to read ‘size and condition’.
184) Are there any further issues for planning policy that we need to consider as we take forward the implementation of Environmental Delivery Plans?
No further comment.
