Local Plan to 2030 Regulation 19 - Publication June 2016

Comment ID ALP/1512
Document Section Local Plan to 2030 - Publication Draft TOPIC POLICIES SECTION D - THE NATURAL AND BUILT ENVIRONMENT Biodiversity and Landscape Dark Skies Content View all on this section
Respondent CPRE Kent (Ashford District Co… View all by this respondent
Response Date 09 Aug 2016
Do you consider this part of the document is Sound? No
On which grounds do you consider the document unsound? (if applicable)
  • Not Consistent with national policy
Do you consider the Document is Legally Compliant? Yes
Comment

This is an excellent policy and is broadly supported by CPRE.  Two amendments are, however, proposed.  

It is requested that the following text is added to the end of the second paragraph of the policy:  ‘….and that no significant adverse effects individually or cumulatively will result to the character of the area, the residential amenity of local residents, the safety of vehicle users and pedestrians, or the feeding, roosting and breeding activities, or the diurnal rhythms of the Borough's biodiversity assets’.

The policy should specifically mention the Kent Downs AONB and the High Weald AONB

The supporting justification does not explain the importance of dark skies to wildlife.  Additional supporting justification could helpfully be provided at Paragraph 5.319.

 

What changes do you suggest to make the document legally compliant or sound? It is requested that the following text is added to the end of the second paragraph of the policy: '....feeding, roosting and breeding activities.... '. (see Comment text which uses the editor).

The policy should specifically mention the Kent Downs AONB and the High Weald AONB

Insert the following at Paragraph 5.319.

“Artificial light disrupts natural patterns of night and day, disrupting feeding, breeding and roosting/resting activity of numerous species. Populations (such as moths which are attracted to artificial light) can be reduced and fragmented. Many flying insects attracted to artificial lights will die as a result of exhaustion. Lack of sleep is detrimental to the survival of birds and disrupts circadian rhythm that dictates the onset of the breeding seasons”.
Do you consider it necessary to participate at the oral part of the examination? Yes
Does your representation relate to an omission site (a site that has not been included). For example a site for Housing, Employment, Travellers, or Local Green Spaces. No
Please supply details of the omission site.
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