Response from Ms Kim Wisdom, Lancashire Wildlife Trust
1. Ms Kim Wisdom, Lancashire Wildlife Trust : 19 Dec 2017 09:57:00
Before completing this online representation please tick the box to show that you have read the guidance notes accompanying this consultation.
I have read the guidance notes
Policy Reference
AS04 - Natural Environment
1.3 Do you consider the AONB DPD to be sound?
No
1.4 If NO please indicate the ground(s) on which you consider the DPD to be unsound
The DPD is not justified
The DPD is not effective
The DPD is not consistent with national policy
1.5 Please give details of why you consider the DPD is not legally compliant or is unsound or fails to comply with the Duty to Cooperate. Please be as precise as possible.
If you wish to support the legal compliance or soundness of the DPD or its compliance with the Duty to Cooperate, please also use this box to set out your comments.
Further to your consultation on the above, this is to confirm that The Wildlife Trust for Lancashire, Manchester & North Merseyside is broadly content with the draft and supportive of the policies on nature conservation, as far as those go.
However, we have one major reservation: the DPD lacks any identification of (and supporting justification for) the conjoined ecological networks within and adjoining the AONB and straddling the two districts and counties. This identification and justification is required in order that these may be effectively and efficiently protected, maintained, enhanced, restored and, where practicable, reconnected and expanded in association with development (planning conditions and obligations, and CIL where relevant) and also through and in concert with other mechanism outside the planning system (e.g. targeted agri-environment support to individual landowners and managers). Identification of such networks is necessary to afford certainty when seeking to restore and improve ecosystem functionality within and across the AONB.
As the National Planning Policy Framework requires such a network to be identified* to assist the Government’s ambition to leave nature in a better state than we find it**, we believe the Development Plan to be unsound and un-evidenced in that particular cross-boundary regard.
*The planning system should contribute to and enhance the natural and local environment by: protecting and enhancing valued landscapes….; recognising the wider benefits of ecosystem services; minimising impacts on biodiversity and providing net gains in biodiversity where possible... including by establishing coherent ecological networks that are more resilient to current and future pressures’ (NPPF paragraph 109)
**‘moving from a net loss of bio-diversity to achieving net gains for nature’ - making a direct reference to the Natural Environment White Paper. (NPPF Paragraph 9)
You should consult your local authorities’ respective ecological advisers in respect of this, and also the site-specific allocation policies.
Please tick the box if you wish to be notified when the document is submitted, recommendations published and adopted.
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