Harborough Local Plan 2011-2031, Proposed Submission

This does not do enough, you should be promoting a net gain of biodiversity - in the Open Spaces Strategy 2016 to 2021, you recognised that Harborough is 'relatively poor in biodiversity and geodiversity terms', you should be trying to improve this. Paragraph 114 of the NPPF states that LPAs should 'set out a strategic approach in their Local Plans, planning positively for the creation, protection, enhancement and management of networks of biodiversity and green infrastructure'. The bullet points after this issue do not do enough to comply with the NPPF. 'Safeguarding the recognised areas of high biodiversity and geodiversity' is not enough, you should be creating new habitat, linking areas of habitat and improving existing areas of habitat.

LRWT agree with the contents of this objective. However, the Harborough Local Plan Proposed Submission does not appear to be trying to comply with this objective - it should aim for net gains of biodiversity and all of the aspirations in objective 6. The rest of the Harborough Local Plan Proposed Submission does not appear to be sufficient to live up to the wording on objective 6; it appears to be aiming for 'not net loss' which is not sufficient for a District that is 'relatively poor in biodiversity and geodiversity terms' (from Harborough the Open Spaces Strategy 2016 to 2021). See paragraphs 114 and 117 of the NPPF.

The Harborough Local Plan should be 'planning positively for the creation, protection, enhancement and management of networks of biodiversity and green infrastructure', (NPPF paragraph 114). To do this they should be aiming for a net gain in biodiversity - creating habitats. Existing habitats should also be managed appropriately. They should also '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; promote the preservation, restoration and re-creation of priority habitats, ecological networks and the protection and recovery of priority species populations, linked to national and local targets, and identify suitable indicators for monitoring biodiversity in the plan; aim to prevent harm to geological conservation interests' (NPPF paragraph 117). This is not just mapping what you have but looking at habitat networks and corridors, planning should include habitat mapping and habitat permeability modelling. This should all be actively promoted in the Local Plan, also biodiversity should be monitored to comply with the NPPF.

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.

Should include 'and sites that meet local wildlife site (LWS) criteria and local BAP priority habitats and species' - a lack of designation does not indicate that a site is not valuable to wildlife - it may just indicate that a site has not been surveyed, so any surveys should consider whether it meets LWS criteria or is a LBAP species or habitat.

Paragraph 114 of NPPF states 'set out a strategic approach in their Local Plans, planning positively for the creation, protection, enhancement and management of networks of biodiversity and green infrastructure'. Therefore, to protect a site, it should be surveyed to identify its worth. If a site meets Local Wildlife Site criteria, it should be viewed as a LWS for planning purposes.

This should be modified. To be able to do this, a mapping exercise should identify 'strategic biodiversity networks and corridors'. This would be compliant with the NPPF, 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 word 'opportunity' does not suggest the Harborough Borough Council is really committed to improving biodiversity and geodiversity. 9.9.2. States that Harborough is relatively poor in biodiversity, so this policy should aim for net gains in biodiversity and improving the District for biodiversity, not just 'retains wherever possible'. Paragraph 117 of the NPPF states 'To minimise impacts on biodiversity and geodiversity, planning policies should: promote the preservation, restoration and re-creation of priority habitats, ecological networks and the protection and recovery of priority species populations, linked to national and local targets, and identify suitable indicators for monitoring biodiversity in the plan'. We would like to see more proactive wording used here, key issue 5 of this plan has aims of -'addressing the biodiversity deficit in the District'. Therefore there should be a proactive approach to aim for a net gain of biodiversity area of good quality, connected habitats.

THIS COMMENT IS FOR 9.9.5
As stated before mapping of existing corridors should be done and this would help to inform the provision of / enhancement of blue or green corridors. See paragraph 117 of the NPPF regarding mapping.

We would welcome this but wish to point out the Harborough District Council have not contacted LRWT 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. As mentioned before, mapping of habitats and habitat permeability would be a good place to start as per paragraph 117 of the NPPF.

How will it be implemented...
We would like to see more here to comply with NPPF paragraph 117 - '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; promote the preservation, restoration and re-creation of priority habitats, ecological networks and the protection and recovery of priority species populations, linked to national and local targets, and identify suitable indicators for monitoring biodiversity in the plan'.
At present the wording of the Harborough Local Plan does not appear to be committed to addressing the biodiversity deficit in the District.

Please note that LRWT are identified as Partners in Objective 7 of the Open Space Strategy, 2015, 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 / true partnership work to benefit biodiversity and habitats.

We welcome this but feel that this does not do enough. To be in line with paragraph 114 of the NPPF, 'planning positively for the creation, protection, enhancement and management of networks of biodiversity and green infrastructure', the wording could be changed from:

'greenways for walking, cycling and horse riding, as part of a central green spine distributor route through and beyond the site, to provide structure to the distribution of development and incorporate most existing hedgerows, trees, field ponds, and footpaths'

To:
'greenways for walking, cycling and horse riding, as part of a central green spine distributor route through and beyond the site, to provide structure to the distribution of development and incorporate most existing footpaths. In addition existing hedgerows, trees and field ponds will be protected, enhanced and managed, where this is not possible, mitigation will be provided to give a net gain in biodiversity overall.'