9.1.1 to 9.1.4 Explanation

Inconsistent with national policy - The NPPF states that local planning authorities should plan for the 'creation, protection, enhancement and management of networks of biodiversity and green infrastructure'. It also states planning policies should promote the preservation, restoration and re-creation of priority habitats, ecological networks and the protection and recovery of priority species populations. We do not feel that this section goes far enough. 'Taking opportunities' leaves too much to chance (it is also not 'promoting' as the NPPF states), it does not suggest that the Council will actively seek to create, protect, enhance and manage networks of biodiversity and GI, just take opportunities as they appear - if no opportunities appear, then will anything happen? The LPA needs to plan positively to create, protect, enhance and manage networks of biodiversity and GI to comply with the NPPF.

LRWT do not think that enough has been done to identify and map 'wildlife corridors and stepping stones that connect them and areas identified by local partnerships for habitat restoration or creation'. This policy (GI1) aims to provide for the natural environment (objective 6), but should start by identifying corridors and also carry out habitat permeability mapping to inform joining of habitats and enhancing areas of habitat.

We would like to see an up-to-date habitat network map produced to identify areas of strategic GI importance for their biological value.
Paragraph 117. Of the NPPF states that 'To minimise impacts on biodiversity and geodiversity, planning policies should: ● identify and map components of the local ecological networks, including the hierarchy of international, national and locally designated sites of importance for biodiversity, wildlife corridors and stepping stones that connect them and areas identified by local partnerships for habitat restoration or creation'.

The policies map identifies wildlife sites of national and local designation, which goes some way towards complying with the NPPF, however wildlife corridors and stepping stones have not been identified on this map.

We note that historical Phase One habitat mapping has been done but is likely to be out of date now. A Phase One habitat survey was carried out in 2008 by wyg for Harborough District Council. This identified wildlife corridors. Since this survey was carried out, the Planning Policy Statement 9 (PPS9) has been replaced by the National Planning Policy Framework (NPPF, 2012), also habitats and land use may have changed as the mapping used aerial photography from 2006.

The Harborough Local Plan Proposed Submission has not mentioned any habitat mapping. It has mentioned corridors but not how these corridors were identified. We would like to see an up to date habitat network map produced along with habitat permeability modelling to identify areas of strategic GI importance for their biological value as well as areas of opportunity to enhance and join up existing habitats.

NPPF also states that Local Plans should plan positively for management of networks. Management of GI networks, especially those which benefit wildlife is not mentioned.

9.1.2 lists LRWT as a partner organisation, we do not object to this but wish to point out the Harborough District Council have not contacted us personally. We may be included on email circulations but have not received any personal day-to-day contact from officers or elected officials. The use of 'partners' or 'partnership' with relation to the current situation should be taken as the broadest use of these terms, although we would welcome more interest / partnership work to benefit biodiversity and habitats.