Local Plan to 2030 Regulation 19 - Publication June 2016

Comment ID ALP/1894
Document Section Local Plan to 2030 - Publication Draft TOPIC POLICIES SECTION D - THE NATURAL AND BUILT ENVIRONMENT Content View all on this section
Respondent Kent Wildlife Trust (Vanessa Evans) View all by this respondent
Response Date 10 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

Kent Wildlife Trust would like to express a general view on arable land loss, as it applies to a large number of proposed allocations in Ashford, in addition to allocations that have already been made through the current Local Plan. Kent Wildlife Trust would recommend that ABC should develop an appropriate policy to address the cumulative impact of the loss of arable land and its locally important habitats and species.

This is not captured elsewhere, such as through the protected species legislation. Arable land contains locally important habitats and features such as hedgerows and orchards ("BAP" habitats) and are important areas for species of local importance that depend upon them, particularly those on the section 41 list (previously known as "BAP" species) such as brown hare and hedgehog; in addition to both breeding and overwintering farmland birds, many of which are in steep decline.

Arable land sites should be adequately surveyed for these species wherever possible and where mitigation does not address the loss of locally significant habitat and species, a strategic policy should outline an acceptable approach to compensation measures that could be implemented. This might include, for example, a financial contribution to an environmental enhancement scheme for other remaining arable sites, funded through the CIL mechanism or similar.

This would support the NPPF para 113 and para 114 point 1.

What changes do you suggest to make the document legally compliant or sound? a policy to address cumulative loss of arable land and impact on locally significant species and habitats
Do you consider it necessary to participate at the oral part of the examination? No
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.
Please supply details of the omission site.