Comment

Representation ID: 44322

Received: 27/09/2021

Respondent: Natural England

The following comments are principally focussed on the Integrated Impact Assessment that
accompanies the Spatial Options document. They also reflect Natural England’s response to the
previous consultation on the Draft Sustainability Appraisal Scoping Report (our letter dated 31
January 2017, reference 204441).
IIA Theme – Health and Wellbeing
Natural England’s previous consultation response recommended the adjustment of the Appraisal
Question “Enhance multifunctional green infrastructure networks throughout the plan area?” by
adding a reference to neighbouring authority areas. The amended wording would be:
“Enhance multifunctional green infrastructure networks throughout the plan area and neighbouring
authority areas?”
This adjustment is still considered advisable as green infrastructure networks may well involve land
that extends beyond the District boundary and restricting the provision to the District boundary
could exclude the scope for landscape scale provision. This could be particularly important given
the location of some of the growth options now being considered. It is of note that the
recommended adjustment to the appraisal question was made in the Final Scoping report dated
March 2017.
There is no longer an appraisal question which will consider whether an option promotes the use of
sustainable transport modes such as walking and cycling. Whilst a similar appraisal question
features in the “Climate Change” theme, it would still be a relevant consideration in assessing the
extent to which a proposal meets the Health and Wellbeing IIA Objective.
Lastly it may be worth reviewing the recently published Essex Green Infrastructure Strategy 2020
as this could provide a relevant addition to the evidence base for this aspect of the emerging Local
Plan.
IIA Theme – Landscape
Natural England supports the inclusion of an appraisal question that considers the relationship and
potential impact of any option/proposal on existing areas of tranquility.
IIA Theme – Climate Change
As in its previous response, Natural England recommends the addition of an appraisal question
which will ensure that options are considered in terms of their compatibility with the Essex and
Suffolk Shoreline Management Plan which is specifically referenced in the Spatial Options
document. The following wording is suggested for the appraisal question:
“Support the priorities identified in the Essex and Suffolk Shoreline Management Plan?”
IIA Theme – Biodiversity
Paragraph 179 of the NPPF (Habitats and Biodiversity) is directly relevant to this particular theme
and should be referenced and adjustments are recommended to the appraisal questions to better
reflect the NPPF policy advice in that paragraph.
As indicated in our previous response, Natural England would advise that specific reference is
made to nationally or locally protected sites. In addition, in light of the updated NPPF text, there will
be an increased emphasis on the delivery of biodiversity net gain. The following wording is
suggested for the first appraisal question:
“Avoid, or if not possible, minimise impacts on biodiversity, nationally or locally protected sites, and
pursue opportunities for securing net gains for biodiversity?”