Comment
Number
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2
Comment
Author
Forestry
Commission
Forestry
Commission
Comment
The definition of 'What do we mean by the natural environment?' does not include the term woodland and it should do.
FC would like to highlight the positive impact of woodlands, especially Ancient
Woodlands in addressing Water Framework
Directive (WFD) issues
Proposed response and where applicable, proposed change to text
This section explains what we mean by a 'natural environment' rather than different habitat types that exist. The text explains that no habitat within the borough is entirely natural and on this basis we could mention woodland in addition to heathland but it is not necessary to understand the point being made. No changes required.
Text amended briefly to acknowledge the important role trees/woodlands play in flood control.
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Forestry
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It is also important to highlight the contribution that managed woodlands provide to the local and regional economy in terms of jobs and energy (wood fuel) as well as supporting important habitats for a range of protected species.
Forestry (i.e. trees and woodlands) can provide a way to reduce pollution
(chemicals or fine sediments) from agricultural land and reduce flood risks by planting the right trees in targeted areas.
Connectivity of habitats is very important for the movement of species. Targeted planting of areas to connect important habitats should be considered. These areas could be part of the Borough´s green infrastructure.
Although Trees and Urban green spaces have been included as `Other type of habitat´ and Hedgerows, Ancient and seminatural woodland, and Lowland pasture woodland/parkland have been included as
`Key habitat´ types in the descriptions, plantations and secondary woodlands not only have been excluded but they do not appear as habitats worth to mention. These woodlands/plantations also provide important habitats for many wildlife species
(flora and fauna) and a range of ecosystems as well as many other benefits to the society which could be incorporated into the ecosystem services described in paragraph
The following additional text has been added: 'For example managed woodlands make a contribution to local and regional economies in terms of jobs and energy, in the form of wood fuel, which as a result also supports important habitats for a range of species'.
This section explains that natural ecosystem help make life possible.
The text already includes some examples in what ways ecosystem services benefit everyone. The role of trees and woodlands is not one of the examples used and, although it is known these too are important in helping with diffuse pollution, reducing flood risk etc., it is not considered possible to list every specific example. No changes required.
This section already states the importance of habitat connectivity.
Any targeted planting of areas to connect important habitats is considered and will be actioned within the GI Strategy. No changes required.
Text to describe ancient seminatural woodlands updated to: ‘The great age of ancient semi-natural woodlands means that typically they have been colonised by a far greater range of species than recent secondary woodland, although secondary and some plantation woodlands can also provide important habitats for different species ’.
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10. These woodlands are important destination for the recreational activities of the local community. At the same time, they contribute to the local economy as local contractors work in these plantations/woodlands, harvesting the timber and carrying out conservation work.
The concepts of sustainability and efficient use of resources, including sustainable woodland management, are strongly linked to the support of the local community.
Sustainable woodland management could boost the local economy, as well as contribute towards a sustainable low carbon economy (woodfuel resources).
Pest and diseases such as Chalara and
Phytophthora might have a detrimental effect on biodiversity
FC listed a number of different aims
Text changed to include:
‘Introduced species can also bring new diseases to which native fauna can be highly susceptible ’.
The aims and objectives identified within this section reflect those previously identified by the Natural
Environment Forum therefore it is not considered appropriate to add/amend these since this is a brief update to the previous strategy. When the strategy is rewritten in 2017 we can consider new/different aims and objectives.
Comment already addressed under comment 2 and 3
We would like to highlight the positive opportunities associated with forest, woods and trees in addressing WFD issues, safeguarding clean water supplies, ensuring riparian habitats are more resilient to climate change (e.g. keeping rivers cool initiative) and helping to manage flood risk.
It is also important to emphasize again the contribution that managed woodlands provide to the local and regional economy in terms of jobs and energy (wood fuel) as well as supporting important habitats for a range of protected species. FC will also continue to promote the benefits of riparian woodland more generally in connection with hydromorphology and habitat condition in the riparian zone.
(Linkage of woodland habitat is also very important for wildlife)
This section states that linking of semi-natural areas will be an important component of the borough's network of green spaces rather than listing individual types.
Woodland habitat is important as are hedges, ponds, rivers etc. No changes required.
Targeted woodland creation could provide linkages between important habitats as well as address WFD issues within the catchment areas of the rivers Loddon and
Test. New woodlands or restoration of riparian woodlands could contribute towards the production of biomass. These woodlands will also provide the market driver to restore and maintain active management to many woods and heaths
The aim of the BPAs is to identify and take opportunities to create or restore new/existing habitats and therefore where appropriate these might be woodland habitats. The council would be happy to help encourage using wood fuel where this is appropriate. It is considered this is more of a general comment rather than suggested change to
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(note: in recent years the market for low quality wood biomass from heathland restoration has been Slough Heat and
Power but this has now closed. Heathrow airport is now heated and power, in part, with wood and we will see many more local wood heat systems established, these in particular offer much better margins to better support sensitive and on-going management which will benefit the some of the borough´s habitats (e.g. Thames Basin
Heaths NCA)
EWGS or future new schemes could be a way to encourage landowners to manage woodlands and/or plant new corridors to link habitats. text.
No change to text; this comment is considered to be more of a general consideration. The council works with the Hants Wildlife Trust which encourages private landowners to manage their land for biodiversity benefit and enter their land into stewardship, some of which might be woodland grant schemes.
Some commentators struggled with definitions and the scope of the strategy compared to the Green Infrastructure
Strategy and felt the different focuses of the two documents should be made clearer.
In the light of national policy documents published since 2010 and with the recent completion of a number of key policy documents (including GI Strategy) to underpin a Local Plan which is progressing through the various steps to adoption , it was hoped that LL could become a more focused document with a clearer framework for action. This seems not to be the case
The scope of the strategy is given at the beginning of the document which states that the document sets out how the council will use its resources to help meet its obligations and commitments to the conservation of the natural environment. It defines the natural environment as those areas which are heavily influenced and characterised by the presence of wildlife and the action of natural processes. The strategy focuses on the conservation of such spaces and wildlife whereas biodiversity is just one of many strands within the
Green Infrastructure strategy.
Other key themes within the GI
Strategy are health and recreation; the GI Strategy outlines how green spaces can benefit the health and wellbeing of people as well as biodiversity. There is therefore some cross over but the Living
Landscapes Strategy focuses on actions which purely benefit biodiversity or which would not be included in or covered by other council strategies. Obviously links to both the Green Infrastructure and the forth-coming Tree Strategy have been made. Text amended, however, to make this distinction clearer.
An action plan is included within the strategy which sets out what action the council and/or with its partners will take over the coming 3 years to help deliver its commitments on biodiversity. These are linked to timescales. Where the details of specific projects are already known these are given, however, the
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Basingstoke and much of the document is aspirational, lacking specific targets or pathways.
The fundamental structural weakness of the draft LL , in not providing a coherent spatial and scale framework for analysis means that no clear prioritising is possible, no resource analysis is attempted and therefore specific outcome targets are not well defined. The result is that LL is a weaker general aspirational document. The specific impact of this weakness is commented on section by section below.
The identification of three performance indicators is mentioned - but no base line data seems to be available. council will be expected to report its progress against all actions listed, including those which cannot be more defined because they are more opportunistic, via annual reviews. We are particularly mindful not to include any actions that are purely aspirational and which may be out of the council's capacity to deliver.
The action plan does prioritise actions and whilst no resource analysis is shown within the comment, the actions proposed are ones that can be delivered.
Many aspects of looking after the natural environment are stated to lie outside the council’s influence and therefore this document is limited in the impact it can make. – it would be helpful if these limitations were illustrated or listed, to the extent that they lay within some other body’s influence.
The performance indicators are relatively new and relate to the amount of key habitat lost to development and the amount of habitat created as a result of new developments or other council initiatives. They look at the amount gained/loss over the course of a financial year and therefore comparisons will be possible to be made against the targets associated with each indicator but it’s not possible to give base lined data since it is dependent on the number/location of planning applications received each year.
Within the GI Strategy there is an aim to map all areas of land managed by the council so that the target associated with increasing the amount of council owned land which is managed to benefit biodiversity can be monitored against this initial mapping.
The best way the council can contribute to biodiversity conservation within the borough is through the functions it is responsible for. These include its planning function and the management of its own land holdings. The majority of the borough obviously lies in private ownership and as a result the council has less of an influence within these areas. For example it would be difficult for the council to undertake particular actions to improve the status of farmland birds other than by working with and supporting partners such as the
Hampshire Wildlife Trust who would be in more of a position to do this.
It should be noted that the text relates to much of the 'natural
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The benefits of a natural environment have been well rehearsed and acknowledged in many documents – it may not be necessary to include them in detail in this document. environment' being outside of the council's influence rather than
'aspects of looking after the natural environment' being outside the council's influence.
This revised draft is merely to update the previous strategy to bring it up to date rather than a total re-edit. It is considered appropriate that the benefits of a natural environment should be emphasised within a strategy specifically focusing on the natural environment. Not all readers may be as well informed.
No mention is made that nature has a right to exist of itself without reference to a human context. If not in this document where else would this be stated? wording changed to take into account this comment
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The aim of this section is to set the framework for a discussion of opportunities, options, priorities and actions so there can be a coherent statement of the way forward.
The overview should be drawing together the plethora of categories, designations, initiatives and delivery mechanisms.
Unfortunately this framework is not clear and the maps do not show a coherent analysis of the borough area. Therefore it is impossible to establish what the actual green network is, where there are gaps and where these are significant. - at either the area level or the site network level.
The Introduction notes the creation of LNPs
(local nature partnerships) but where these fit into the scheme of things is not clear.
The text within this section remains as valid as it was when the previous strategy was adopted 3 years ago. Although it is noted that the comment author would like this section to be set out more clearly, the section does provide an overview, with descriptions of key species and habitats followed by designated sites and landscape scale areas. When the next more in-depth revision of the strategy is prepared all sections of text will be fully revised. Information on the proposed action the council will take in relation to any of the features mentioned is given in the later sections. Maps are included to show the AONB, designated sites and landscape character areas in addition to BOAs, BPAs and Hampshire Wildlife Trust project areas. These are overlaid with each other within the GI strategy. In addition maps showing key green corridors are not yet available but their production is an action within the GI Strategy.
The Hampshire LNP has not moved much further forward since it was established in 2012 therefore it is not entirely clear yet what part the council can play in the partnership and what work will be undertaken within the Borough to pursue the
LNP's objectives. As a result it is not possible to give more detail on how the LNP's objectives will fit into the work of the council over the next 3 years other than to list the
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aims and priorities of the LNP should it secure necessary funding/resources to carry out any work. The council is supportive of the LNP's objectives and priorities.
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The lack of base data in the form of maps is a concern. While habitat types are described there are no detailed local maps in the LL document appendixes. While some county scale data is available from elsewhere, it would be useful to reproduce habitat type’s data over the four maps that cover the borough. (See Appendix 2:
Locations of Designated Sites in the Living
Landscape 2010 appendixes.). Having this level of detail would be useful to borough staff as well as parish and other voluntary groups. It would help to put the various habitats in context and will make identifying gaps and the planning of new green corridors, that much easier. It could also be used to assess the potential damage done by new development, and help design meaningful mitigation.
For the LL document to be meaningful, the state and quality of each LNR, SINC & SSSI should be described in high level terms, such as good, fair or poor with an indication of whether it is improving, stable or deteriorating. This data will inform just how much effort will be required to keep these key sites viable. It is understood that data of this type is periodically available (via
HBIC?) but is not used to inform this document.
This data, where it exists, is kept by the Hampshire Biodiversity
Information Centre and can be requested from them. The maps that will appear in the final draft will show all the designated sites within the borough and the main habitat types these are designated for.
Since most key habitats are designated SINCs it is considered adequate mapping showing the location of key habitat types has been provided. As part of action plan for the GI Strategy maps are to be produced showing key green corridors within the borough.
The council currently owns 5 LNRs and 23 SINCs. The condition status of any SINCs or LNRs sites within the Borough is not data that is available for most sites and not for any sites owned by BDBC.
Where this data might exist it will be held by HBIC and only for a small proportion of sites. SINCs/LNRs are re-surveyed and thereby reassessed for SINC status every 5-
10 years for grasslands and every
20 years for woodlands. This could provide some measure of the condition of these sites but won’t for all habitat types.
As a result it is agreed that it would be useful to direct resources into gathering information on the condition status of LNRs managed by the council.
It is recognised that many of the
LNR sites have not received the level of management they require in the past. The production of new management plans for these sites will help ensure that they will receive appropriate management in the future. Furthermore, future management plans will include an element of monitoring which will assess the impacts of the management on the nature
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While there is a “Local Policy Context” there is no “National Policy Context” that highlights the borough’s statutory responsibility and obligations for Local
Nature Reserves (LNR’s) and SSSI’s.
Without knowing the level of resource the borough is obligated to, the Action Plan has little meaning other than a “wish list”.
Similarly any obligations under the
European Water Framework Directive need to be stated.
While one of the stated aims of the strategy is joined up thinking and the creation of green corridors to eliminate isolation of quality green spaces there are little mention of and certainly no map of where these green corridors are or should be, either at landscape level or sub-landscape level, to create a spatial framework. conservation interests of the site.
The condition of SSSIs is provided on Natural England's website.
BDBC is directly responsible for one SSSI (Pamber Forest) which is meeting or moving towards meeting favourable conservation status. It would not be considered appropriate to list the conservation status of all other SSSIs within the borough since their direct management is out of the control of the council unless partnership working can help make improvements.
Within the introduction, the national policy drivers and legislation in relation to biodiversity are given, these being the NERC Act, the
Natural Environment White Paper and Biodiversity 2020. However it is primarily local policies, as set out in the strategy, which have informed the strategy. Under their designations as LNRs, the council is required to actively manage the sites for nature conservation interest. Currently the management on most of the council's LNRs is carried out by conservation volunteer groups with support from the council's
Operations team. Management plans are to be produced for those lacking a management plan or where an existing plan is out of date. Text has been added to highlight the responsibility of the council to manage these sites for the nature conservation interest for which they were designated.
Similarly, additional text has been added to highlight the council's responsibilities relating the
European Water Framework
Directive.
Mapping of key green corridors within the borough is an action to be delivered through the Green
Infrastructure Strategy
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The Key Habitat types listed and described in these paragraphs are taken from Section
41 documentation. The inclusion of the
‘other’ habitat types, (in para 47 – 54) are a welcome acknowledgement that, in this borough at least, the urban environment is very green and of significant environmental quality and has the potential to be
It is unclear where the commentator is suggesting these sub-headings should go; however, some of the key habitat types occur within the urban environment, for example
South View Cemetery is designated for its chalk grassland interest and lies in the heart of Basingstoke.
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Basingstoke considerably more bio-diverse. We would simply make a plea for the subheadings to acknowledge the worth of these areas as:
Habitat Types - Countryside [or Rural] and
Habitat Types – Urban.
Greenways and green corridors are listed as aesthetically a ‘good thing’ and the role of river corridors is rightly emphasised. But the role of the network of green spaces throughout the Basingstoke urban area, especially in the south and west of the town is not mentioned. Carefully managed, these green corridors could provide a vital habitat link between the country edge and the more built-up areas.
Disturbance from human activity DOES
(not can) have a negative impact – there are no two ways about it and we should acknowledge the fact.
The biggest threat to the natural environment comes from the expansion of commercial development and housing – this is not mentioned.
Water Availability and Quality & Pollution identifies the threat. Nowhere in the document is the use of Sustainable
Drainage Systems (SUDS) mentioned as an approach. Elements of SUDS can be used to create new habitats both within urban areas and along flood plains. The potential for green spaces to act as storage areas and sub-surface reservoirs of run-off will prevent water being “wasted” to surface drainage. They can also be used to cleanup grey water, prior to discharge in rivers.
As green spaces that are subject to annual or irregular inundation, they may provide vital wet land habitat even close to the town centre.
Similarly gardens within rural areas can be just as important as those with the urban environment. As a result no change to text has been made.
Text changed to include suggestion made.
The impact from human disturbance is specially highlighted because it is acknowledged this can have a negative impact.
However, there may be instances where so long as this access is controlled and managed sensitively to avoid, for example, key breeding seasons some access may be possible.
Within the section on Planning it is acknowledged that new development and construction can have a sudden and severe negative impact on the natural environment if they are not carefully planned and in the wrong place. However, text has been updated within this section to include the comment made.
This section covers the key threats to biodiversity rather than all the mitigation measures to overcome them. The use of SUDs and the benefits they provide is given in the council's Biodiversity and
Landscape SPD which specifically addresses planning issues.
Conservation Approach - Borough Land:
This is where the council has ownership and therefore control over the actions taken in managing these sites. There are a number of statements of intent with which few could disagree but the metrics are not very helpful. How do the sites fit into a coherent network? What are the priorities between sites - resources are scarce so there must be some prioritising? The paragraph announcing the appointment of 1 biodiversity operative for the whole borough area may be a 100% increase on resource
Land managed by the council does not necessarily form part of a coherent network because of the way the land has come across to the council - such as adoption by the council following development in locations which do not readily link to existing green space. Within the
GI Strategy the development of management plans for sites owned by the council has been prioritised.
Reference to current staff resource has been removed from text to
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Basingstoke heretofore but is nothing to write home about - since the borough has reduced the number of green rangers from 3 in the early
2000s to 1 community development officer for green spaces in 2011.
While the document mentions LNRs at various points the role of the LNR status is not prominently discussed. Our understanding is that this status (public ownership and an obligation to manage for biodiversity) is one of the few mechanisms which put biodiversity and nature conservation ahead of all other considerations for the site. The pressures on green spaces are many (as listed before in the document) and the expansion of this mechanism for long term management and security of bio-diverse rich sites should be emphasised as the primary mechanism available to the council and to be used wherever possible. avoid confusion since the council’s commitment to biodiversity goes beyond dedicated staff resource and includes service budgets to implement the necessary management plans for council owned wildlife sites. It is recognised, however, that work still needs to be done to look at how existing resources can be better targeted at biodiversity.
Work to look at connecting up sites where possible forms part of the
Green Infrastructure Action Plan. .
The council has a NERC Act duty to consider biodiversity across all of its functions. To this end the council is currently in the process of writing management plans for all of its key green spaces with a biodiversity interest. The management of these sites will be tailored to the particular biodiversity interest of the site. The council is aware that in designating sites as
Local Nature Reserves, the nature conservation interest of the site which has formed the basis of the designation will generally take precedence over any other use/interest of the site. As a result the council is developing criteria to aid the identification of new LNRs so that consideration of any conflicting interests can be taken into account.
Text changed to express number of people over 1 year this figure equates to.
When discussing the contribution of voluntary conservation resources a figure of
7,644 hours is mentioned. It would be helpful to also translate this into man/years.
(a suggested net 30 hrs per week for 42 productive weeks per year would give a value of 6 man/years). However, in reality this effort is not all directed to working hands-on with the natural environment - there is a significant element of community outreach and environmental care for the benefit of residents rather than wildlife. we reject the statement in para 73 ‘Green
Infrastructure, which essentially means the multi-functional open space required to meet the needs of local people, is an important component of any planning for future growth.’ When, elsewhere in the GI
Strategy document, the definition of green infrast ructure is declared to be: ‘Green
Infrastructure is a network of green spaces and other environmental features which provides a multi-functional resource for the benefit of the environment and quality of life for communities. GI can include parks, open spaces, playing fields, woodlands, allotments and private gardens.’
Text changed to reflect definition given in the GI Strategy.
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Landscape & Biodiversity in the Countryside
(para 74 – 84) - This section lists various designations and the management arrangements for projects in these areas - usually in the hands of HIWWT. It is not clear what the actual contribution of the council is in these cases other than to bestow its blessing and reflect designation in developing and exercising planning controls - is there any other contribution?
Para 84, for example aspires to ‘habitat enhancements and creation along the corridors of the River Loddon and River
Test which have been identified as
Biodiversity Priority Areas (BPAs)’ - what, in practice, will the council contribute?
Working with the Community ( para 85 in the greater area green networks, part of the green corridors between urban green sites, connecting people to the natural environment, preserving remnant biodiversity hot spots, objectives where benefits to the natural environment are incidental to community health and wellbeing.
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91): The final section dealing with natural environment considerations in the urban environment contains a series of ongoing projects without any framework which indicates how these contribute to the wellbeing of the natural environment. Links
While each task in the Action Plan is given a
“priority”, there is no high level indication of what resources (staff/volunteer time & capital/revenue) will be involved. Without this data it is not possible to make sensible judgements over what habitat improvement projects are feasible.
1) Any project takes resources in the form of time (staff, volunteer or partner) and money
(capital & revenue). Each project will have its own timeline and the results can be judged against stated quality criteria.
Without high level resource (time & money) “budgets” put against each of the activities in the Action Plan, it would be difficult to do “gap” analysis. With an idea of
This section recognises that other organisations may be better placed to help in the conservation of the natural environment within the wider borough context. By supporting schemes such as the
Loddon and Eversley Heritage Area
Initiative the council is demonstrating its commitment to the consideration of biodiversity across the whole of the borough.
The council supports different partners, such as the Hampshire
Wildlife Trust, which are better placed to effect land use change beyond the council's role as a local planning authority, through funding and by helping to steer work programmes. The council would look to try and support any initiatives which will help deliver habitat targets within the BPAs when opportunities arise. This could be through partnership working, securing habitat creation linked to new development or in the management of the council's own land holdings within these areas.
Within this section the text highlights the importance of local communities in the stewardship of local environments and in turn the benefits this can provide. The benefits to people are also highlighted within the section titled
'The Benefits of the Natural
Environment'. The contribution local communities make to the long-term conservation of the natural environment is also specifically highlighted. The actual benefits well looked after green spaces and the contribution these make to the 'greater area green networks' is covered in section 47 -
Urban Green Space but further text has been added to this section to emphasise this further.
Many of the proposed actions are already included within the council’s programme of works, and as these are ongoing tasks, it is not considered necessary to provide any more assessment of the resource required.
However, it is acknowledged that the delivery of the action plan will need to take advantage of the different types of delivery mechanisms identified, and in some instances these are already in place. For actions that are not already within the council’s
‘ongoing’ work programme, it is
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38 Basingstoke
Field Society what resource short-falls there are, putting project plans together becomes a lot easier.
2) When it comes to biodiversity and wildlife projects, the borough has a number of delivery mechanisms: a) The use of its own staff to develop, manage and implement these projects
(example??) b) The use of its own staff and volunteers to develop, manage and implement these projects (existing conservation groups) c) The use of third sector agents to run the day-to-day management of sensitive sites. For example, the use of Hampshire &
Isle of Wight Wildlife Trust to manage large sites such as Pamber Forest. d) The use of developer funding to commission third parties to develop, manage and implement mitigation projects associated with new builds. (The Crested
Newt mitigation at Marnel Park being an example of good practice.) e) The use of central government funding in partnership with public bodies such as the Environment Agency, to develop, manages and implements these projects. (Eastrop Park/Town Brook/River
Loddon project) f) There may be others delivery mechanisms of which members of Natural
Basingstoke are not aware
3) Given the boroughs own very limited internal resources, the only way it can contemplate making significant inroads into its own Action Plan is to use a combination of third sector and commercial environmental organisations. These would need to be grant funded on a project by project basis.
The way for that to be economically justified would be to start with a well defined and costed project, use a third party resource to acquire funding and then third party resources to deliver, all under the supervision of a dedicated borough staff member.
We are in agreement with your strategy proposed that one of the first tasks following the adoption of the action plan will be to develop more detailed project briefs and to identify the most appropriate form of delivery. It is considered that this would be required for some actions such as developing criteria to identify new Local Nature
Reserves, identifying key green corridors in the borough, producing a new SPD and providing Parish
Councils with advice on their NERC
Act Duty.
No changes to text have been made.
Point noted and welcomed.
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