Comment

Representation ID: 99423

Received: 19/12/2022

Respondent: Natural England

Natural England commend the consideration of our comments during the initial consultation on the NMWLP in 2018, which has resulted in the removal of MIN 71 and MIN 204 as they are considered unsuitable due to the potential for adverse effects on designated sites.
Nature Recovery Network (NRN) and Local Nature Recovery Strategies (LNRSs)
Natural England commends the NMWLP for acknowledging the potential that restoration and after-use of mineral workings has for the benefit of enhancing landscape, geodiversity and biodiversity. We welcome the reference to contributing, “to identified strategic green infrastructure corridors and known ecological networks,” made in Policy MP7. We would advise that reference to the Nature Recovery Network [https://www.gov.uk/government/publications/nature-recovery-network/nature-recovery-network] is also included in the Plan vision (pg. 19). The NRN is a commitment in the government’s 25 Year Environment Plan and enacted by the Environment Act 2021. Natural England is working with partners on NRN and the development of LNRSs [https://consult.defra.gov.uk/land-use/local-nature-recovery-strategies/] . The NRN is used to refer to a single, growing national network of improved joined-up, wildlife rich places which will benefit people and wildlife. LNRSs will be the key mechanism for planning and mapping local delivery of the NRN.
LNRSs will form a new system of spatial strategies for nature that will be mandated by the Environment Act. They will cover the whole of England and will be developed by Responsible Authorities (RAs) appointed by the Secretary of State, usually at a county scale. Each strategy will:
• Map the most valuable existing habitat for nature
• Map specific proposals for creating or improving habitat for nature and wider environment goals
• Agree priorities for nature’s recovery
LNRSs have also been designed to help local planning authorities deliver existing policy on conserving and enhancing biodiversity and to reflect this in the land use plans for their area.
Biodiversity Net Gain (BNG)
In line with paragraph 174(d) of the NPPF, reference to providing BNG is made throughout the NMWLP, which Natural England commends. BNG will be an important tool in securing investment for nature recovery through the planning system, helping deliver the government’s commitment to create a national NRN. However, we advise strengthening this wording by stating the minimum BNG uplift required to be delivered. With regards the upcoming mandatory requirement for a minimum of 10% BNG, we advise that you consider BNG delivery above this level, for example at 15% or 20% BNG. Strategic level viability assessments in Kent have concluded that this shift will not impact viability in most cases irrespective of onsite or offsite BNG delivery. This is because after the initial cost of securing the minimum 10% BNG, the cost of increase to 15 or 20% is much less and generally negligible. Natural England’s Biodiversity Metric 3.1 may be used to calculate biodiversity losses and gains for terrestrial and intertidal habitats and can be used to inform any development project.
It is the government’s intention that mandatory BNG will provide a financial incentive for development to support the delivery of LNRSs through an uplift in the calculation of biodiversity units created at sites identified by the strategy through the Biodiversity Metric ‘strategic significance’ scoring.