BHCC Biodiversity and Nature Conservation SPD: What is it and how can you respond?
Brighton and Hove City Council have now released their Biodiversity and Nature Conservation supplementary planning document and we as a group will be putting in a response to this document. We wanted to share with you a breakdown of what’s in the document. It’s hard to be brief so we’ve done the best we can to make this as succinct and accessible as possible. It’s also hard to be impartial but we’ve done our best!
The main documents reference in this post can be found here:
If you read this and feel that you would like to respond to the document, the survey can be found here: https://consultations.brighton-hove.gov.uk/planning/draft-bnc-spd-consultation/
Responses need to be submitted by Monday 22nd March.
A quote from the document to get us started:
‘Brighton and Hove is a vibrant biodiverse living landscape, rich in biodiversity from peregrines on tower blocks to rare leeks on the vegetated shingle beaches. The city is formed of the interconnected and interweaving urban areas, including the city’s parks and greenspaces, coastal, marine, and chalk downland habitats, allowing wildlife to move, migrate and thrive. Even seemingly sterile environments can provide a haven for wildlife, with buildings providing important nesting and roosting habitats for birds and bats, and street trees, churchyards and urban gardens supporting species such as hedgehogs, butterflies and fungi.’
Now for some definitions…
Biodiversity, natural environment and nature = used interchangeably in the document to refer to mean,
‘living things such as plants, insects, animals, birds and fish that are interconnected and all part of our city’
‘Habitat and conditions that are required for all living things to thrive, such as healthy soils, fresh air and clean water, as well as open green space, grasslands, shrubs, woodland, aquatic, marine and coastal environments’
Net gains: where the biodiversity losses are outweighed by the gains; the aim is to leave the land in a better state than it was. This can be through off-site mitigation (see below), land management initiatives and the like
Mitigation: measures to avoid, reduce, mitigate and compensate for likely adverse effects on ecological receptors arising from the construction of the authorised development
Protected, priority and notable species: species recognised by law as being significant and in need of awareness, monitoring and protection e.g. hedgehogs, badgers,
Priority habitats: as above but for habitats. Includes calcareous soil favoured by a number of wildflowers and pollinators and chalk grassland.
What is a Supplementary Planning Document (SPD)?
The SPD is a document created by BHCC, Place Services Essex CC and East Sussex CC to, ‘assist planning applicants and developers understand the importance of nature and how development can help deliver biodiversity improvements and net gains.
Who will use the SPD?
Planning applicants and their design teams
Residents, amenity groups and any groups commenting on planning applications
What the above means for us as a group and you as a resident:
When you are commenting on any planning proposal, you will be able to refer to this document in raising questions about its ecological viability e.g. will it destroy an area in which nature thrives? Will there be any way of ‘mitigating’ that destruction? Will any developments/extensions/proposals take the existing wildlife population into account e.g. will they use bee bricks, create hedgehog highways, incorporate nesting sites and wildflower sites into plans?
You will be able to use this document to ensure that developers are held accountable to their words surrounding sustainability and ecologically sound developments.
Some points raised in the document (and I’m keeping this as brief as I can!):
Page 5: Brighton and Hove is a designated ‘The Living Coast Brighton’ and as a UNESCO Biosphere region (Lewes Downs)
Page 5: The city is a popular place and, with demands for housing, has a constrained land supply therefore competition for land is high
Page 6: ‘...climate change and associated biodiversity declines are attributed to human causes. Habitats and species once considered to be common in the city are facing increasing stresses with many at breaking point.’ Our badger and hedgehog population are two that spring to our minds.
Page 6: ‘The Corporate Plan 2020 sets out priorities to support the objective of becoming a sustainable city including the commitment for the city to become carbon neutral by 2030.’
Page 6: Aim of SPD is to set out guidance and best practice advice
Page 6: SPDs will be given ‘significant weight’ to plans such as the City Plan Parts 1 and 2 (the proposed development of 100 dwellings at Benfield Valley is on part 2)
Page 9: Benfield Valley is sited as a Local Green Space
Page 17: The Benfield Valley (known on the maps as ‘Benfield to Hangleton’) is sited as a Biodiversity Opportunity Area (BOA), which are ‘likely to form the basis of future local Nature Recovery Networks
Page 19: 5.1 The mitigation hierarchy. This is taken from the National Planning Policy Framework (NPPF), paragraph 180, and details the hierarchy in aiming to harm and conserve and enhance biodiversity. This is shown in figure 5 (see below). Applicants must show how their developments comply with the hierarchy.
Page 21: 5.3 Local biodiversity matters:
Protection of irreplaceable habitats
Habitats regulations assessment
Recreational pressure on designated sites including SSSIs (Sites of Special Scientific Interest)
Conservation of the marine environments
Wildlife sensitive lighting
Great Crested Newt licensing
Page 24-32: Integrating biodiversity into development
Butterfly and bee banks
Bug-hotels and log piles
Biodiverse roofs and walls
Sustainable drainage systems
Page 33: Step-by-step guide to biodiversity and development management process
Responding to the SPD
As I have said in previous consultations that we have responded to, we cannot tell you what to say, but we can let you know what issues we will be raising. These are as follows:
In section 4.32 (Future Local Nature Recovery Strategy) on page 17, the Biodiversity Opportunity Areas Map (see map below)) states that the area highlighted in yellow (Benfield to Hangleton) is one such area. A BOA is an area where ‘habitat enhancement, restoration and creation will have the most benefit in enhancing connectivity and improving resilience of species populations.’ This directly contradicts the fact that a large section of the Benfield Valley, mostly woodland, has been earmarked for the development of 100 dwellings on the City Plan Part 2. Clarity needs to be given as to whether development of a space marked as a BOA, either now or in the past, is appropriate. Will this area remain a BOA and be afforded the protective measures that this would bring, as it rightly should?
2. If the area Benfield to Hangleton is stated as a BOA then it should fall under the heading of ‘Avoidance’ in the mitigation hierarchy stated in figure 5 on page 19 of the draft consultation. This would create a case for its removal from the City Plan Part 2. Please provide further clarity on this.
3. This section also makes reference to the future Local Nature Recovery Network and we would like assurance that the council will work with local groups such as ourselves and the Benfield Hill LNR group to strengthen and enhance this strategy. We would also like clarification as to how Benfield Valley, a green lung for our community and for the city as a whole, will play its part in this LNRN if it has been interrupted by the building of 100 dwellings, effectively cutting the space in two, thereby creating further disparity in the connectivity of our local green spaces.
4. Please provide clarity as to when ecological surveys will be undertaken for proposed developments. These must not be done at inappropriate times of the year.
5. Where off-site mitigation is stated e.g. translocation of reptiles and/or mammals, what measures will be in place for ensuring that these communities are thriving and not, as has been the case in some areas, killed off by the experience? Who will be accountable for this
6. What measures will be in place to ensure that mitigation and protection measures are adhered to? What will be the repercussions if developments do not adhere to them? Who will hold them to account? What will the complaints procedure be and will it be possible for local residents to comment if they are unsatisfied with developments?
We really hope that you are able to do what you can to respond to this document as it will inform future planning proposals in Brighton and Hove. We will be responding as a community group and each as individual residents.
This could be an incredible opportunity for the ecological health of the city and the subsequent impact that this has on our human community as well as our ‘wild’ community. We have always said that we understand and support the need for new, affordable housing but do not believe that we should be sacrificing our precious local green spaces in order to fulfil unrealistic targets, especially in areas like Hangleton, which is one of the most deprived in the UK.
Any questions, or if you need any support in responding to the consultation, please do message here on the website or on firstname.lastname@example.org
Thanks for reading!
The BVP Team
Map of BOAs in Brighton and Hove