Aylesbury Vale Area

VALP Proposed Submission

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VALP Proposed Submission

NE2 Biodiversity and geodiversity

Representation ID: 658

Received: 14/12/2017

Respondent: Royal Society For Protection Of Birds (RSPB)

Representation Summary:

The RSPB welcomes and strongly supports Policy NE2 as an appropriately rigorous, detailed and sensible response to halting the further loss of biodiversity from the District due to development. In future, the Council's ability to deliver this policy effectively will depend significantly on retaining in-house ecological expertise, and a properly resourced biological/LWS recording and designation system in Aylesbury Vale, and on a well thought out and properly justified system of biodiversity accounting.

Full text:

The RSPB welcomes and strongly supports Policy NE2 as an appropriately rigorous, detailed and sensible response to halting the further loss of biodiversity from the District due to development. Such losses are well documented. We are pleased to note that the policy is consistent with the suggestions previously made by the RSPB in respect of the draft Local Plan, in September 2016 (namely, to require all new development to achieve a net gain in biodiversity, and to adhere to the "mitigation hierarchy" set out in NPPF section 118). See copy of letter attached, dated 19 September 2016.

While not strictly relevant to this consultation we feel it is worth highlighting the importance for AVDC of retaining access to independent ecological expertise. AVDC is one of a diminishing number of local authorities with such expertise retained within its staff team. The success of Kingsbrook for one example has been in significant measure due to AVDC's in-house ecological expertise.

We also feel obliged to point out, however, that for as long AVDC declines to provide funding to enable records of Local Wildlife Sites and Biological Notification Sites to be properly surveyed and updated, the weaker its position will become in resisting speculative development that is likely to have direct or indirect impacts on such sites. The Council will instead become ever more reliant on developers' own assessments of the significance of the impact of their own proposals (which realistically almost always under-play the significance of the impact, and over-play the certainty with which such impacts can be mitigated or compensated for). The Council's ability to discharge its legal obligations in respect of the conservation of biodiversity may thereby be eroded over time, and while organisations like the RSPB will do what we can to support the Council's decisions with evidence, we are not able to replace a properly resourced biological/LWS recording and designation system in Aylesbury Vale.

Finally, with any future biodiversity SPD in mind (as outlined in paragraph 9.17 of the Plan) and in relation to the reference to "biodiversity accounting" in clause (a) of Policy NE2, we offer the following thoughts on achieving true net gain in biodiversity, and recommended approaches to biodiversity offsetting. We raise these points not because a change to the Local Plan is required, but because in the end, the successful implementation of policy NE2 will require significant further detail to be developed and applied through SPD.

There are many tools available around net gain, and offsetting is often seen as a part of this. Such tools must be statutorily underpinned, with proper application of the mitigation hierarchy to result in a true net gain for biodiversity rather than undermining it. Approaches to net gain must be applied outside statutory designated sites, where existing and more robust protections already apply. Such approaches must be compatible with and not alternative to regulatory standards relating to statutory designated sites. Furthermore, development near statutory designated sites should be required to pass an additionality test that recognizes existing obligations to achieve and maintain favourable ecological condition.

Proper understanding of the baseline environment is essential (considering the importance, condition and irreversibility of existing habitat) and the mitigation hierarchy must be rigorously applied. This point underscores again the importance of ensuring that good ecological advice remains available to the Council, and of funding a robust LWS/BNS system in the Vale.

There should be standard methodology for assessing impact to ensure consistency across all developments and monitoring what is actually delivered on the ground is key. It is also important to think about how habitats created for wildlife will be managed for wildlife in perpetuity and protected from future development (ideally through policies in the local plan). In short, habitat created to mitigate or compensate the damage caused by one development must not be lost to other developments (or neglect) years later.

The results of Defra's biodiversity offsetting pilot projects (which the RSPB had serious concerns with) highlight that considerable evidence gaps remain, particularly with regard to offset delivery and management.

Biodiversity offsetting should only ever be used for projects that have rigorously applied the mitigation hierarchy and must always be a measure of last resort (i.e. after all efforts to avoid or mitigate harm through appropriate location and design have been exhausted). Re-creating or restoring complex natural processes is inherently difficult and full of risk, even where habitats are nominally seen as "replaceable". As such, in-situ conservation is always preferable.

Biodiversity offsetting is not appropriate in all circumstances, in particular where the risk of offset failure is high and/or where offsetting is infeasible such as in the case of threatened species or 'irreplaceable' habitats such as ancient woodlands. Part of the development of any offsetting system must include a systematic, evidence-led assessment of the feasibility of restoring or creating habitats successfully, including for the species/species communities dependent on them.

Support

VALP Proposed Submission

D1 Delivering Aylesbury Garden Town

Representation ID: 660

Received: 14/12/2017

Respondent: Royal Society For Protection Of Birds (RSPB)

Representation Summary:

The RSPB welcomes and strongly supports many of the principles built into draft Policy D1. In particular we support the clear aspiration to achieve high quality development (a); promote sustainable travel choices (f); and (especially) achieve a minimum 50% land as multifunctional green infrastructure which maximises benefits such as wildlife, recreation and water management (h). The 50% green infrastructure threshold is truly visionary, and may be resisted by development interests, but the experience gained at Kingsbrook shows this is achievable, and as importantly demonstrates the social and environmental value (difficult to monetize) of such benefits to existing and new communities.

Full text:

The RSPB welcomes and strongly supports many of the principles built into draft Policy D1. In particular we support the clear aspiration to achieve high quality development (a); promote sustainable travel choices (f); and (especially) achieve a minimum 50% land as multifunctional green infrastructure which maximises benefits such as wildlife, recreation and water management (h). The 50% green infrastructure threshold is truly visionary, and may be resisted by development interests, but the experience gained at Kingsbrook shows this is achievable, and as importantly demonstrates the social and environmental value (difficult to monetize) of such benefits to existing and new communities.

Support

VALP Proposed Submission

D-AGT1 South Aylesbury

Representation ID: 662

Received: 14/12/2017

Respondent: Royal Society For Protection Of Birds (RSPB)

Representation Summary:

The RSPB particularly supports clauses G and H of this allocation/policy. For the rationale, please refer to our comments on draft Policy D1 and the attached letter dated 19-9-16.

Full text:

The RSPB particularly supports clauses G and H of this allocation/policy. For the rationale, please refer to our comments on draft Policy D1 and the attached letter dated 19-9-16.

Support

VALP Proposed Submission

D-AGT3 Aylesbury north of A41

Representation ID: 663

Received: 14/12/2017

Respondent: Royal Society For Protection Of Birds (RSPB)

Representation Summary:

The RSPB particularly supports clauses E and O of this allocation/policy. For the rationale, please refer to our comments on draft Policy D1 and the attached letter dated 19-9-16.

Full text:

The RSPB particularly supports clauses E and O of this allocation/policy. For the rationale, please refer to our comments on draft Policy D1 and the attached letter dated 19-9-16.

Support

VALP Proposed Submission

D-AGT4 Aylesbury south of A41

Representation ID: 664

Received: 14/12/2017

Respondent: Royal Society For Protection Of Birds (RSPB)

Representation Summary:

The RSPB particularly supports clauses D and H of this allocation/policy. For the rationale, please refer to our comments on draft Policy D1 and the attached letter dated 19-9-16.

Full text:

The RSPB particularly supports clauses D and H of this allocation/policy. For the rationale, please refer to our comments on draft Policy D1 and the attached letter dated 19-9-16.

Support

VALP Proposed Submission

D-AGT6 Kingsbrook

Representation ID: 665

Received: 14/12/2017

Respondent: Royal Society For Protection Of Birds (RSPB)

Representation Summary:

The RSPB particularly supports clauses D and H of this allocation/policy. For the rationale, please refer to our comments on draft Policy D1 and the attached letter dated 19-9-16.

Full text:

The RSPB particularly supports clauses D and H of this allocation/policy. For the rationale, please refer to our comments on draft Policy D1 and the attached letter dated 19-9-16.

Support

VALP Proposed Submission

D3 Housing development at smaller villages

Representation ID: 667

Received: 14/12/2017

Respondent: Royal Society For Protection Of Birds (RSPB)

Representation Summary:

The RSPB supports this policy as it would appear to rule out the prospect of large scale speculative development, particularly in ecologically sensitive locations such as at Calvert. The RSPB has previously expressed its opposition to further development in this location following a site visit accompanied by the Council's ecologist earlier in 2017.

Full text:

The RSPB supports this policy as it would appear to rule out the prospect of large scale speculative development, particularly in ecologically sensitive locations such as at Calvert. The RSPB has previously expressed its opposition to further development in this location following a site visit accompanied by the Council's ecologist earlier in 2017.

Support

VALP Proposed Submission

NE9 Trees, hedgerows and woodlands

Representation ID: 668

Received: 14/12/2017

Respondent: Royal Society For Protection Of Birds (RSPB)

Representation Summary:

The RSPB supports draft policy NE9 as part of a coordinated approach to ensuring no net loss of biodiversity to development, and to helping deliver a net gain.

Full text:

The RSPB supports draft policy NE9 as part of a coordinated approach to ensuring no net loss of biodiversity to development, and to helping deliver a net gain.

Object

VALP Proposed Submission

C3 Renewable Energy

Representation ID: 669

Received: 14/12/2017

Respondent: Royal Society For Protection Of Birds (RSPB)

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

While we support the intention behind policy C3 we feel we must question whether, in practice, it will lead to any decisions allowing any significant renewable energy scheme in the lifetime of this Plan. The need to act positively and quickly is so overwhelming that we advocate a different approach based on spatial planning to identify areas where applications for renewable energy developments of different types will be positively welcomed by the Council. We refer to the RSPB's 2050 Energy Vision report for a possible model to take forward.

Full text:

While we support the intention behind policy C3 we feel we must question whether, in practice, it will lead to any decisions allowing any significant renewable energy scheme in the lifetime of this Plan.

The severity of the impacts of climate change and the urgency with which we must tackle both the causes (mitigation) and the effects (adaptation) are now almost universally recognized and supported by an overwhelming weight of scientific evidence. These effects are already being felt locally, nationally and globally and are likely to become significantly more frequent, and much worse, within the timespan of this draft Plan. The plan needs to adopt a more positive and proactive approach and the council needs to be prepared to make some difficult choices if it is to play its part in mitigating the causes of climate change.

We have two concerns that could be addressed:

Firstly, while the policy begins by "encouraging" renewable energy development at the beginning, the practical combined effect of all the subsequent conditions set in the policy might well be to rule out any significant renewable energy development.

Secondly, "encouraging" feasibility assessments for district heating and CHP for certain forms and scales of development is laudable, but the council will not be able to "require" them based on the policy as worded. And we also question the likelihood of any feasibility study that is not subject to independent expert scrutiny concluding that DH/CHP options for any development are in fact, "feasible". It would require extraordinary vision from any developer to result in any such scheme becoming reality.

Instead of the criteria-based policy currently proposed, we strongly urge the Council to follow a spatial approach to identifying renewable energy using a spatial methodology similar to that advocated in the RSPB's 2050 Energy Vision. The summary report is at http://ww2.rspb.org.uk/Images/energy_vision_summary_report_tcm9-419580.pdf and the full technical report at http://ww2.rspb.org.uk/Images/energy_vision_technical_report1_tcm9-419581.pdf. Please see recommendation #2 in the summary report in particular. We accept that the report is focused mainly on ecological constraints but there is no reason why other constraints (e.g. Green Belt, landscape, historic heritage) etc could not also be incorporated into the methodology. We also accept this would be significant new work for the Council to undertake but if the net result of the policy as proposed now is no renewable energy development of any significance, then this ought not to be an acceptable outcome to the Council.

Support

VALP Proposed Submission

I1 Green infrastructure

Representation ID: 670

Received: 14/12/2017

Respondent: Royal Society For Protection Of Birds (RSPB)

Representation Summary:

The RSPB welcomes and strongly supports draft policy I1. For the rationale, please refer to our comments on draft Policy D1 and the attached letter dated 19-9-16.

Full text:

The RSPB welcomes and strongly supports draft policy I1. For the rationale, please refer to our comments on draft Policy D1 and the attached letter dated 19-9-16.

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