Development Management Submission Document

Natural England welcomes the short, medium and long term visions for the district and is broadly in agreement with the policies presented in this section, including those relating to the design of new developments, light pollution and telecommunications. However, we advise you to refer to our previous response regarding recommendations for changes in wording within Objective 7 (previously 8), Draft Policy DM1 and Paragraph 2.39, Environmental Zone 1 (in relation to lighting). We note our changes have been incorporated into the Telecommunications section. It is important to ensure that the retention of the green belt is not at the expense of areas that support wildlife within the town, including locally designated wildlife areas (local wildlife sites/county wildlife sites), brownfield sites and undesignated areas that provide both habitat for wildlife and ecological continuity. Gardens and allotments are also important, both in terms of increasing the biodiversity value associated with new developments and improving the health and wellbeing of residents. We advise that these points should be reflected within the medium/long range vision.

We welcome the short, medium and long term visions, particularly in terms of protecting the openness and character of the greenbelt, green tourism and new strategies for improving access to the countryside. However, we find that, whilst protection for areas of nature conservation is frequently referred to in this section, enhancement is not. We consider that the section should be updated to reflect the need for protection and enhancement, for example in the following sections:

Objective 1 should read as follows:
'Continue to protect and enhance biodiversity whilst protecting the openness and character of the District's Green Belt'.

In the Green Tourism section (page 46), we would recommend that a paragraph is added detailing how funds raised by green tourism may be used to protect and enhance sites of ecological importance.

We also recommend that further provisions are included in Draft Policy DM23, Conservation Areas and the Green Belt, to protect and enhance areas of biodiversity and geodiversity interest when defining what should be considered acceptable development.

Also note our comments in the previous section regarding brownfield sites and ecological linkages.

We broadly agree with the vision, objectives and policies in this section, including Policy DM27, Species and Habitat Protection, Policy DM25 Trees and Woodlands and Policy DM26, Other important landscape features. In our view the policies in this section are all well considered and sufficiently comprehensive.

We recommend that Point 3 in the short term vision should read:
'Local, national and international sites of nature conservation importance are protected and enhanced.' It is noted that enhancement is included as a medium term aim, but enhancement should actually be reflected in current, as well as in future decision making.

Natural England advises you to add a bullet on improving ecological connections between local and national sites and the wider countryside, which should build in detail over the short, medium and long term visions. This is in view of the aims of the NPPF to improve the network of wildlife areas within the UK, in accordance with the findings of 'Making Space for Nature' (2012) and the Natural Environment white paper (2012).