Comment

Representation ID: 44845

Received: 11/10/2021

Respondent: Ruskin Properties

The principle of protecting nature conservation is supported by the draft policy but there are concerns that the policy as drafted does not sufficiently distinguish the hierarchy of national and locally designated sites with a disproportionate amount of protection afforded to non- statutory sites.
In terms of criteria 3), this states that where, exceptionally, the strategic benefits of a development outweigh the importance of a local nature site, that any remaining impacts, including any reduction in area, must be fully mitigated. No definition is given as to what the strategic benefits of a development would be with this policy lacking clarity in terms of how it is intended to be implemented.
The policy does should also add in a further criterion that acknowledges that to remediate degraded, derelict, or unstable site will often result in a negative impact upon nature conservation that is inevitable. In these circumstances, where this relates to a non-statutory site, development should be permitted if the benefits of the development outweigh harm when the development is taken as a whole and as evidenced through documents submitted in support of planning applications.

Support is given to the BCA updating its evidence on designated nature conservation sites in conjunction with its partners and with the amendment to existing designations in accordance with this evidence. This evidence has not been undertaken regularly during the current period of the Development Plan resulting in out-of-date evidence that does not correlate to the nature conservation value of sites within the plan.