Local Plan to 2030 - Main Modifications September 2018

Document Section Main Modifications to Ashford Local Plan Policy HOU10 – Development of residential gardens (MM66) Policy HOU10 – Development of residential gardens (MM66) [View all comments on this section]
Comment ID MMLP/130
Respondent Environment Agency (Jennifer W… [View all comments by this respondent]
Response Date 29 Oct 2018
Current Status Accepted
To be "Sound" a Plan should be Positively Prepared, Justified, Effective and Consistent with National Policy
Do you consider that this ‘Main Modification’ is sound? No
If you consider this ‘Main Modification’ to be unsound, on which grounds do you consider it so?
  • Not consistent with National Policy
Please give details of why you consider this ‘Main Modification’ to be unsound in accordance with the tests above (if applicable)? MM66 Policy HOU10- Development of residential gardens
The modification to this policy states that “development proposals involving the complete or partial redevelopment of residential garden land will be permitted provided the proposed development complies with: the Council's external space standards as set out in Policy HOU15 and…
d) Does not result in significant harm to wildlife corridors and biodiversity habitats”.

This appears to be contrary to requirements of the National Planning Policy Framework (NPPF), which specifies that not only should development not result in significant harm but, in 170 d) minimise impacts on and provide “net gains for biodiversity, including by establishing coherent ecological networks that are more resilient to current and future pressures”.

Accordingly, this statement is not sound and should be re-written to reflect the requirements of the NPPF.