Aylesbury Vale Area

VALP Further Main Modifications

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VALP Further Main Modifications

FMM098

Representation ID: 3864

Received: 09/02/2021

Respondent: Buckinghamshire and Milton Keynes Natural Environment Partnership

Representation Summary:

The NEP formally supports the following insertion, and Aecom’s comments in relation to it, in their Sustainability Appraisal Addendum (at 9.2.4), to clarify that hard-surfaced areas do not comprise green infrastructure and will not be counted as contributing to GI targets.

FMM 098, MM reference MM 246, Page 299, Section 11.1:

“Open space includes green infrastructure and also civic space including market squares and other hard surfaced community areas used for community activities. However, hard surfaced or civic spaces do not count as providing green infrastructure to meet Policy I1.”

Full text:

Dear VALP Further Main Modifications Consultation Team,

I’ve attached for your attention the response from the Bucks & MK NEP to the Further Main Modifications consultation in respect of the VALP.

I’d be grateful if you could please acknowledge receipt.

The NEP supports most of the proposed further main modifications to the text at Policy NE1 (FMM096, MM228, Page 266, Policy NE1, Biodiversity and Geodiversity) – except for:
a. The proposed insertion at NE1 (c)
The SPD should be focused on Biodiversity Net Gains – and not on “biodiversity and geodiversity” for the purpose of clarity, and in line with practice. (This has also been picked up by Aecom in the Sustainability Appraisal Addendum);

and

b. The following requested wording amendments, for the purposes of clarity, to the text at NE1 (i): to ensure that it’s the NEP’s Biodiversity Action Plan that is being referred to; and to ensure that it’s not just BOAs, but the “other areas of local biodiversity priority” also being referred to throughout this section; and to make it clear that net gains cannot just be achieved through a focus on biodiversity opportunity areas and other areas of biodiversity priority, but the objectives of the BAP could be achieved elsewhere, outside those areas, too.
c. The NEP also suggests reference to supporting the objectives of the forthcoming Local Nature Recovery Strategy for Buckinghamshire is a considered within the text.

The NEP formally supports the following insertion, and Aecom’s comments in relation to it, in their Sustainability Appraisal Addendum (at 9.2.4), to clarify that hard-surfaced areas do not comprise green infrastructure and will not be counted as contributing to GI targets.

FMM 098, MM reference MM 246, Page 299, Section 11.1:

“Open space includes green infrastructure and also civic space including market squares and other hard surfaced community areas used for community activities. However, hard surfaced or civic spaces do not count as providing green infrastructure to meet Policy I1.”


Suggested additions in yellow; suggested deletions in red (Officer note: see attached representation form for formatting)

NE1 (c )
“These gains must be measurable using best practice in biodiversity and green infrastructure accounting…to be set out in a future Supplementary Planning Document the Biodiversity and Geodiversity SPD Accounting SPD.
NE1 (i)
“Planning conditions/obligations will be used to ensure net gains in biodiversity by helping to deliver the Buckinghamshire and Milton Keynes Natural Environment Partnership’s Biodiversity Action Plan targets in the biodiversity opportunity areas and other areas where biodiversity priorities can be delivered, including in areas of local biodiversity priority. Where development is proposed within, or adjacent to, a biodiversity opportunity such an area, biodiversity surveys and a report will be required to identify constraints and opportunities for biodiversity enhancement. Development which would prevent the aims of a Biodiversity Opportunity Area, and other areas that can deliver local biodiversity priorities, from being achieved will not be permitted. Where there is potential for development, the design and layout of the development should secure biodiversity enhancement and the Council will use planning conditions and obligations as needed to help achieve the aims of the biodiversity opportunity area. A monitoring and management plan will be required for biodiversity features on site to ensure their long-term suitable management (secured through planning condition or Section 106 agreement)”

Object

VALP Further Main Modifications

FMM096

Representation ID: 3865

Received: 09/02/2021

Respondent: Buckinghamshire and Milton Keynes Natural Environment Partnership

Legally compliant? Not specified

Sound? No

Representation Summary:

The NEP supports most of the proposed further main modifications to the text at Policy NE1 (FMM096, MM228, Page 266, Policy NE1, Biodiversity and Geodiversity) – except for:

a. The proposed insertion at NE1 (c)
The SPD should be focused on Biodiversity Net Gains – and not on “biodiversity and geodiversity” for the purpose of clarity, and in line with practice. (This has also been picked up by Aecom in the Sustainability Appraisal Addendum);

and

b. The following requested wording amendments, for the purposes of clarity, to the text at NE1 (i): to ensure that it’s the NEP’s Biodiversity Action Plan that is being referred to; and to ensure that it’s not just BOAs, but the “other areas of local biodiversity priority” also being referred to throughout this section; and to make it clear that net gains cannot just be achieved through a focus on biodiversity opportunity areas and other areas of biodiversity priority, but the objectives of the BAP could be achieved elsewhere, outside those areas, too.
c. The NEP also suggests reference to supporting the objectives of the forthcoming Local Nature Recovery Strategy for Buckinghamshire is a considered within the text.

Change suggested by respondent:

Suggested additions in yellow; suggested deletions in red (Officer note: Please see attached representation form for formatting to changed text)

NE1 (c )
“These gains must be measurable using best practice in biodiversity and green infrastructure accounting…to be set out in a future Supplementary Planning Document the Biodiversity and Geodiversity SPD Accounting SPD.
NE1 (i)
“Planning conditions/obligations will be used to ensure net gains in biodiversity by helping to deliver the Buckinghamshire and Milton Keynes Natural Environment Partnership’s Biodiversity Action Plan targets in the biodiversity opportunity areas and other areas where biodiversity priorities can be delivered, including in areas of local biodiversity priority. Where development is proposed within, or adjacent to, a biodiversity opportunity such an area, biodiversity surveys and a report will be required to identify constraints and opportunities for biodiversity enhancement. Development which would prevent the aims of a Biodiversity Opportunity Area, and other areas that can deliver local biodiversity priorities, from being achieved will not be permitted. Where there is potential for development, the design and layout of the development should secure biodiversity enhancement and the Council will use planning conditions and obligations as needed to help achieve the aims of the biodiversity opportunity area. A monitoring and management plan will be required for biodiversity features on site to ensure their long-term suitable management (secured through planning condition or Section 106 agreement)”

Full text:

Dear VALP Further Main Modifications Consultation Team,

I’ve attached for your attention the response from the Bucks & MK NEP to the Further Main Modifications consultation in respect of the VALP.

I’d be grateful if you could please acknowledge receipt.

The NEP supports most of the proposed further main modifications to the text at Policy NE1 (FMM096, MM228, Page 266, Policy NE1, Biodiversity and Geodiversity) – except for:
a. The proposed insertion at NE1 (c)
The SPD should be focused on Biodiversity Net Gains – and not on “biodiversity and geodiversity” for the purpose of clarity, and in line with practice. (This has also been picked up by Aecom in the Sustainability Appraisal Addendum);

and

b. The following requested wording amendments, for the purposes of clarity, to the text at NE1 (i): to ensure that it’s the NEP’s Biodiversity Action Plan that is being referred to; and to ensure that it’s not just BOAs, but the “other areas of local biodiversity priority” also being referred to throughout this section; and to make it clear that net gains cannot just be achieved through a focus on biodiversity opportunity areas and other areas of biodiversity priority, but the objectives of the BAP could be achieved elsewhere, outside those areas, too.
c. The NEP also suggests reference to supporting the objectives of the forthcoming Local Nature Recovery Strategy for Buckinghamshire is a considered within the text.

The NEP formally supports the following insertion, and Aecom’s comments in relation to it, in their Sustainability Appraisal Addendum (at 9.2.4), to clarify that hard-surfaced areas do not comprise green infrastructure and will not be counted as contributing to GI targets.

FMM 098, MM reference MM 246, Page 299, Section 11.1:

“Open space includes green infrastructure and also civic space including market squares and other hard surfaced community areas used for community activities. However, hard surfaced or civic spaces do not count as providing green infrastructure to meet Policy I1.”


Suggested additions in yellow; suggested deletions in red (Officer note: see attached representation form for formatting)

NE1 (c )
“These gains must be measurable using best practice in biodiversity and green infrastructure accounting…to be set out in a future Supplementary Planning Document the Biodiversity and Geodiversity SPD Accounting SPD.
NE1 (i)
“Planning conditions/obligations will be used to ensure net gains in biodiversity by helping to deliver the Buckinghamshire and Milton Keynes Natural Environment Partnership’s Biodiversity Action Plan targets in the biodiversity opportunity areas and other areas where biodiversity priorities can be delivered, including in areas of local biodiversity priority. Where development is proposed within, or adjacent to, a biodiversity opportunity such an area, biodiversity surveys and a report will be required to identify constraints and opportunities for biodiversity enhancement. Development which would prevent the aims of a Biodiversity Opportunity Area, and other areas that can deliver local biodiversity priorities, from being achieved will not be permitted. Where there is potential for development, the design and layout of the development should secure biodiversity enhancement and the Council will use planning conditions and obligations as needed to help achieve the aims of the biodiversity opportunity area. A monitoring and management plan will be required for biodiversity features on site to ensure their long-term suitable management (secured through planning condition or Section 106 agreement)”

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