Lowland Derbyshire and Nottinghamshire Local Nature Partnership
Nicola SworowskiNG2 Business
Planning Policy Manager8 Experian Way South Derbyshire District Council Nottingham
Civic OfficesNG2 1EP
Civic Way
Swadlincote
Derbyshire
DE11 0AH
7th October 2015
Dear Ms Sworowski,
RE: Sustainability Appraisal Addendum Local Plan Part 1 (Unmet Housing Need)
The Lowland Derbyshire and Nottinghamshire Local Nature Partnership will support the District Council to achieve sustainable development through strategic local planning. We aim to ensure that your area’s natural environment assets (i.e. natural capital) are accounted for in strategic planning so that they can support people both economically and socially. The Local Nature Partnership (LNP) has identified eight natural capital assets in our area which through ecosystem services provide essential goods supporting your local economy and people. Your plan can impact the condition of your capital which is essential for long term sustainable economic growth. During plan preparation, therefore, your strategic objectives, local plan and Sustainability Appraisal (SA)must ensure adequate consideration of your natural capital and where it needs to be increased, maintained or improved to ensure your development proposals are sustainable, and long term environment and economic costs are prevented or minimised.
We have reviewed the SA addendum and in conjunction with the original SA Report and Local Plan submitted in August 2014 make the following responses.
Duty to Co-operate
The LNP was formed and in existence from October 2012. We have no record of a request under the duty to co-operate for both the original SA and the local plan preferred options statutory consultation (regulation 18).
Can you clarify if your duty with regard to the LNP was discharged from January 2013?
Strategic objectives
The LNP welcomes the strong sustainability tone in the local plan and that several objectives (objective 1, 3, 7, 8 and 9) have a sustainability element to development that includes “safeguarding natural resources” and “promoting design excellence”. The LNP views the safe guarding of natural resources as a primary objective to ensure that their condition does not deteriorate and impact on those ecosystem services that support local economic growth or the health and well-being of the local population. In order to ensure development is sustainable it is of upmost importance that the South Derbyshire District Council has a full understanding of its natural capital assets, their extent and condition and howthe local plan will affect them.
Natural Capital
We appreciate the evidence gathering and evaluation the Council has undertaken for some natural capital assets. We note the following:
(a)Minerals: We welcome the safe guarding policy with regard to minerals and coal reserves. The local plan and SA do not identify the full extent of the mineral resource and reserves. We recognise that they should be identified in the County Council mineral plan and the LNP will review it to ensure it has taken adequate consideration of the extent of mineral resources and reserves and that the safe guarding policy is adequate. However it is not clear from the SA if the local plan development impinges on ever mineral resource or identified reserves,other than a statement of no safe guarding issue have been identified in Section 7.40.8.
Can you share the spatial distribution and extent of your mineral resource and reserves and if development impinges either, including any areas identified for unmet housing need?
(b)Sub-soils: We acknowledge the importance of the geological and archaeological features in the area and that you have identified Regional Important Geological sites within your land characterisation. In both the plan and SA we could not identify the location and distribution of RIGs and archaeological sites in relation to the proposed development.
(c)Soil: We welcome the commitment in Policy SD4 to restore contaminated land and derelict and unstable sites. However, the plan and SA do not consider the extent of soil condition across the area, particularly for safe guarding prime agricultural land or ecological communities.
(d)Ecological Communities: We welcome the biodiversity policy and green infrastructure policy within the Local Plan that aims to improve the River Mease(Special Area of Conservation), other statutory and local wildlife sites,and the importance given to improving ecological connectivity which promotes ecosystem resilience. We cannot identify within the plan or SA the full extent and spatial distribution of its ecological habitats outside the statutory sites and local wildlife sites. Indeed both Policies have particular regard to statutory sites, local wildlife sites and the National Forest area only. No consideration of habitats outside these sites can be a constraint to achieve your sustainable development goals over the medium to long term.
(e)Species: Other than reference to statutory sites and Local Wildlife Sites the most critical species and their spatial distribution and location have not been identified in the plan or SA.
(f)Water:We welcome the clear identification of water resource availability concerns, flood risks, and the nitrate and phosphate contamination in some key rivers. It is recognised that the development plan for areas north of Burton will be unsustainable by 2028 for water supply. Again it is unclear from the SA the extent and condition of both groundwater and surface water bodies, including rivers across the area.
(g)Air: Current air quality condition and the impact that the development plan will have on existing Air Quality Management Areas (AQMAs) or the potential to create new AQMAs is unclear in the development plan and SA. This appears to be a significant omission.
(h)Land:We welcome the emphasis in Policy BNL4 to maintain South Derbyshire’s landscape character and the use of landscape character assessments. However the results of the character assessments for each development proposal in the SA and technical appendices, and how the character will change and/or the mitigation measures that would need to be applied, is unclear.
The LNP recognises that SDDC is close to its plan adoption. We, therefore, recommend that you include within your post adoption monitoring and future strategic planning the quantity and spatial distribution of your eight natural capital assets. This natural capital information is held by the LNP and supporting stakeholders such as Natural England, the Environment Agency, Forestry Commission and Derbyshire County Council. Some of it is included in your evidence base and the LNP can support you in this area. The LNP is developing its strategy to identify how to increase, maintain and enhance our areas natural capital to ensure that development is sustainable. We will share this strategy you in due course.
Impact of unmet housing need
We are, therefore, concerned that there is limited evidence on the full extent and condition of South Derbyshire’s natural capital preventing a full assessment of the impact of the local plan and the proposed unmet housing need increase of 2995 from 9,605 dwellings to 12,600 dwellings. It is unclear from the Addendum what impact the additional dwellings will have on your natural capital.
Can you clarify the impact, positive and negative, that the additional housing will have on the natural capital in your area?
The LNP would appreciate a constructive dialogue with South Derbyshire District Council that through mutual co-operation delivers a sustainable development plan to serve the people of South Derbyshire and their future generations.
I trust our response will help you deliver your goal to achieve sustainable development. I would be grateful if you acknowledge receipt of our response. The LNP is looking forward to working with you. If you have any further questions do not hesitate to contact Rosy Carter our LNP co-ordinator at the above address.
Yours sincerely,
Tony Walker, Chair, Lowland Derbyshire and Nottinghamshire LNP board
Tony Hams, Vice-Chair, Lowland Derbyshire and Nottinghamshire LNP board