Part One: Spatial Strategy and Policies (Regulation 18)

Comment

Representation ID: 669

Received: 22/12/2023

Respondent: Natural England

We are disappointed that no polices specially address soil protection or loss of best and most versatile agricultural land. We acknowledge that compared to other areas there is limited best and most versatile agricultural land in the plan area. We would still advise adding in a policy for soil protection that includes best and most versatile agricultural land, in line with the National Planning Policy Framework and the government’s 25 Year Environment Plan.
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The Local Plan should give appropriate weight to the roles performed by the area’s soils. These should be valued as a finite multi-functional resource which underpin our wellbeing and prosperity. Decisions about development should take full account of the impact on soils, their intrinsic character and the sustainability of the many ecosystem services they deliver, for example:
• Safeguard the long term capability of best and most versatile agricultural land (Grades 1, 2 and 3a in the Agricultural Land Classification) as a resource for the future.
• To avoid development that would disturb or damage other soils of high environmental value (e.g. wetland and other specific soils contributing to ecological connectivity, carbon stores such as peatlands etc) and, where development is proposed.
• Ensure soil resources are conserved and managed in a sustainable way.
We would advise that the plan refers to sources of Agricultural Land Classification and Best and Most Versatile mapping and data which will include but not limited to: the MAGIC (defra.gov.uk) website and Natural England. For example Agricultural Land Classification map West Midlands Region - ALC004 (naturalengland.org.uk) and Likelihood of Best and Most Versatile (BMV) Agricultural Land - Strategic scale map West Midlands Region - ALC016 (naturalengland.org.uk).
The plan should recognise that development (soil sealing) has a major and usually irreversible adverse impact on soils. Mitigation should aim to minimise soil disturbance and to retain as many ecosystem services as possible through careful soil management during the construction process. We advise that policy should support developments that enhance soils, avoid soil sealing and provide mitigation to avoid soil disturbance.
We advise that Plan policies refer to the Code of practice for the sustainable use of soils on construction sites - GOV.UK (www.gov.uk) and that major development should have a soils management plan.