New Local Plan: Spatial Options Document 2021
Thank you for this opportunity to respond to the latest consultation. Our comments follow those made on previous
consultation documents, namely:
1 July 2015 – Draft Environmental Capacity Study
18 May 2016 – Draft Statement of Community Involvement
8 March 2018 – Issues and Options consultation.
Please find our responses to particular questions below.
Q1. Are there any other technical evidence studies that you feel the Council needs to prepare to inform its new
Local Plan, other than those listed in this section?
As mentioned in our letter responding to the draft Environmental Capacity Study, full consideration should be given
to the Environment Agency’s Essex and South Suffolk Shoreline Management Plan.
Q4: Do you agree with the strategic priorities and objectives we have identified?
Yes. We welcome and commend the Council’s clear priority in Strategy Priority 5 to conserve and enhance the natural
environment as well as a clear ambition to create habitat networks. This is consistent with national planning policy.
Q31. Do you consider net gains for biodiversity are best delivered on-site or off-site? Are there specific locations or
projects where net gain projects could be delivered?
Mandatory biodiversity gain (BNG) should go beyond mitigating and compensating the impacts of development by
enhancing natural capital, supporting the recovery of nature and meeting future environmental challenges. Done
correctly, it should help to deliver sustainable development, restore nature, and create and enhance places where
people live and work.
The council’s approach to BNG should be underpinned with clear targets for protecting and restoring biodiversity and
its effectiveness evaluated on a regular basis. BNG must be in addition to, and not instead of existing statutory
biodiversity protection and it should only apply to developments that do not have an impact on protected areas, e.g.
Special Protection Areas (SPAs), Special Areas of Conservation (SAC), Ramsar sites and Sites of Special Scientific
Interest (SSSIs).
A fundamental risk of BNG, is that it will be considered a licence to trash habitats as destruction of a habitat can be
offset by creation of another. To avoid this, the net gain approach must apply and enforce the mitigation hierarchy,
so all efforts are made to avoid and mitigate harm through appropriate location and design choices. Compensation (offsetting) of residual impacts on habitats and species should be a last resort. Re-creating or restoring complex
natural processes is inherently difficult and full of risk so in-situ conservation is always preferable. Once the mitigation
hierarchy has been strictly applied, the development should be achieving no net loss of biodiversity. Net gain
approaches can then be explored as additional
To answer the question specifically, where new habitat is created, it is normally preferable to do so on the
development site. If this is not possible or desirable due to unavoidable impacts, it should be in an area identified in
a local or strategic biodiversity enhancement plan (e.g. the evolving Local Nature Recovery Strategies [LNRS]).
Q32. With reference to the options above, or your own options, how do you feel that we can best deliver a quality
green and blue infrastructure network through the plan?
The RSPB would like to see a strategic approach adopted for the delivery of new and enhanced green and blue
infrastructure. We are currently working with a number of partners in Essex to establish a Local Nature Partnership
(LNP) as well as the evolving process of Local Nature Recovery Strategies (LNRS) which have recently been piloted
elsewhere in the UK.
Protecting and enhancing the established network of designated sites is the fundamental first step. It is widely
recognised that much of the land surrounding our coastal SPAs and SSSIs is functionally-linked to these sites (i.e. it is
unprotected land that supports numbers of birds such as dark-bellied brent geese in significant numbers). Identifying
and mapping these areas at a spatial-level would assist the council in maximising the benefits to the natural
environment
Q33. Do you agree that the central woodlands arc and island wetlands, shown on Figure 32 are the most
appropriate areas for new regional parklands? Are there any other areas that should be considered or preferred?
The RSPB supports the recognition giving to the network of coastal sites in the “island wetlands” complex which are
reflected by their suite of national and internationally important nature conservation designations.
However, it is critical that the sensitivity of the internationally important species and habitats is accounted for
rigorously in the planning of any such proposals. A Habitats Regulations Assessment (HRA) of the plan should be
instigated at the earliest opportunity in order to achieve this. Responding to the Issues and Options consultation in
March 2018 in relation to HRA, we said:
“We recognise that a number of HRAs relating to previous development plans and strategies have been
provided as part of the evidence base. Whilst informative, these are not up to date. However, we note and
welcome your commitment to presenting a draft HRA at the next stage of the plan process (per paragraph
1.12) and we look forward to commenting on this document. If you require any assistance in its formation,
we would be happy to assist.”