COTSWOLDS CONSERVATION BOARD
POSITION STATEMENT
Biodiversity Planning
Introduction
1.
Areas of Outstanding Natural Beauty (AONBs) are designated by the Government
for the purpose of ensuring that the special qualities of the finest landscapes in
England and Wales are conserved and enhanced. In policy terms they have the
same planning status as National Parks.
2.
In the Cotswolds AONB, the planning system has been essential in conserving and
enhancing the special qualities of the landscape.
3.
The Cotswolds Conservation Board is the body set up by Parliament to conserve
and enhance the natural beauty1 of the Cotswolds AONB and increase the
awareness and understanding of the special qualities of the AONB. It has a duty to
have regard to the social and economic needs of those who live and work in the
Cotswolds.
4.
The Cotswolds AONB Management Plan 2008-132 notes that:
“While the protection and management of important sites and species is an essential task, it
is also important to improve the quality of habitats in the wider landscape. This needs to
involve both enlarging and linking important habitats that are fragmented or isolated,
restoring those which are damaged or degraded, and improving the quality of the
surrounding environment to sustain the wildlife outside of them and to allow natural
movement across the landscape in response to forces like climate change and human
pressures.”
Policy DTP1 of the plan states:
“That all Local Development Framework documents and planning decision-making
processes will use the following criteria to determine the acceptability of a
proposed development in the Cotswolds AONB. Development will: …

Protect, or where possible enhance, biodiversity;…”
1
The National Parks and Access to the Countryside Act (1949) (as amended by the Countryside
Act (1968), section 49(4)) makes clear that "references to the conservation of natural beauty shall
be construed as including references to the conservation of its flora, fauna and geological and
physiographical features". Therefore the AONB has a statutory role in respect of flora and fauna (or
biodiversity).
2 Cotswolds AONB Management Plan 2008-13, Cotswolds Conservation Board (2008)
http://www.cotswoldsaonb.com/page.asp?pageID=12
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5.
This position statement provides some background to the biodiversity resource in
the Cotswolds AONB, and provides guidance to the local planning authorities on
the conservation and enhancement of that resource through the planning system.
Whilst more information and advice regarding other mechanisms for the
conservation and enhancement of priority species and habitats is provided in the
National, Regional and County Biodiversity Action Plans, the Board considers that
it is important that the distinctive biodiversity of the AONB is conserved in a
consistent manner.3
Background
6.
7.
8.
9.
The Cotswolds AONB supports a range of habitats and a diverse flora and fauna4.
Many of these habitats are under pressure or declining. Frequently the sites
supporting these habitats are the remnants of wider areas of semi-natural plant
and animal communities and result from lower intensity agricultural practices. Key
habitats have shown a decline in extent and sometimes in condition, especially
since the 1940s, mainly as a result of changing farming and land management
practices. Sites have also become more fragmented as this decline has occurred.
Many of the most important areas are now also under threat from climate change.
.
There are five European Special Areas of Conservation (SACs) designated under
national and European legislation within the AONB. They are the Cotswold
Beechwoods (beech woodland), Rodborough Common (limestone grassland),
Bath and Bradford-on-Avon (bats), Dixton Wood (deadwood insects) and Bredon
Hill (deadwood insects).
There are two categories of national statutory site protection which help to
conserve the best wildlife habitats and geological exposures. In the Cotswolds
AONB these are:

three National Nature Reserves (NNRs) – Cotswold Commons and
Beechwoods (near Painswick, Gloucestershire), Bredon Hill (Worcestershire),
and Wychwood Forest (near Witney, Oxfordshire)

Sites of Special Scientific Interest (SSSIs) - 89 in the AONB, including the
NNRs. There are also two Local Nature Reserves (LNRs) in the AONB.
The locations of these sites are shown on the map at Appendix 2. These sites
represent only the remaining fragments of former much more extensive areas of
natural and semi-natural habitat. These fragments are representative of the most
important features in the AONB for nature conservation and are the best examples
of the distinctive character of the Cotswolds wild flora and fauna.
3
Section 40 of the Natural Environment and Communities Act 2006 requires all public bodies to
have regard to the purpose of conserving biodiversity in exercising their functions.
4 A list of the priority habitats and species in the Cotswolds AONB are attached at Appendix 1.
2
10. County Wildlife Sites, Key Wildlife Sites, and Sites of Nature Conservation
Importance are identified by Wildlife Site Partnerships as having local significance
for biodiversity, and they may be of SSSI quality. Sites are also protected due
being ancient woodland, or being owned by organisations such as the National
Trust, Woodland Trust and the Wildlife Trusts.
11. Both national and locally important sites can be highly vulnerable. They are often
small and their quality is threatened or actually deteriorating through airborne
pollution, altered hydrology and changes in land management both within and
around sites. They can also be isolated from each other by inhospitable agricultural
land management practices and by the urban environment, which makes them
even more susceptible to the effects of climate change.
12. In face of such pressures, endangered habitats will not survive through site-based
protection alone. They also need to be expanded by connection across the
Cotswolds AONB and surrounding areas. As well as the planning system there are
a variety of mechanisms through which this broader approach of habitat buffering,
linking and expansion can be achieved. These include agri-environment schemes
and other grant schemes, which are outside the scope of this position statement.
(See paragraph 36).
Spatial planning opportunities
13. The planning system has a key role to play in the conservation and enhancement
of biodiversity in the Cotswolds. The local development framework system for local
planning provides an opportunity for the spatial expression of habitat linkages,
whilst development control can contribute to the delivery of specific proposals.
14. Planning Policy Statement 12 “Local Spatial Planning” states
“2.6. Spatial planning provides a means of safeguarding the area’s environmental
assets, both for their intrinsic value and for their contribution to social and
economic well being by:
• protection and enhancing designated sites, landscapes, habitats and protected
species; and
• creating a positive framework for environmental enhancement more generally. 5”
5
Planning Policy Statement 12 DCLG (2008)
3
15. Planning Policy Statement 9 “Biodiversity and Geological Conservation”6 states:
“5. Local development frameworks should:
(i) indicate the location of designated sites of importance for biodiversity and
geodiversity, making clear distinctions between the hierarchy of international,
national, regional and locally designated sites; and
(ii) identify any areas or sites for the restoration or creation of new priority habitats
which contribute to regional targets, and support this restoration or creation
through appropriate policies.”
16. The Board will encourage local planning authorities to set out in Local
Development Documents clear objectives and policies for landscape scale
habitat restoration and creation.
17. There are different approaches on how this is to be achieved in each of the three
regions covered by the Cotswolds AONB.
18. In the South West Region the South West Nature Map provides a broad-scale,
strategic vision for change which offers a spatially-based tool for identifying where
biodiversity enhancement could be delivered in the future, using existing areas of
wildlife value as a starting point.
19. Therefore the Board considers that within the South West region, the
Wiltshire, Gloucestershire7, Bath and North East Somerset, and South
Gloucestershire authorities should consider using the South West Nature
Map to:
(a) identify areas and sites at the local level in the Cotswolds AONB that can
contribute towards regional targets for the restoration and creation of priority
habitats;
(b) inform the formulation and use of appropriate policies in their LDFs.
20. The Nature Map identifies at the landscape scale blocks of land, known as
‘Strategic Nature Areas’ (SNAs). SNAs represent the best areas to maintain and
expand wildlife habitats through their management, restoration and/or re-creation.
21. SNAs are a practical way of applying a character approach at the landscape scale.
They show the spatial distribution and pattern of priority habitats that are
characteristic of the landscape types of the South West. They demonstrate which
habitat, of regional importance, is most appropriate for restoration and expansion
in any particular local area.
6
Planning Policy Statement 9 DCLG (2005)
http://www.communities.gov.uk/planningandbuilding/planning/planningpolicyguidance/historicenviro
nment/pps9/
7 A more detailed Nature Map has been prepared for Gloucestershire by the Gloucestershire
Biodiversity Partnership. http://www.gloucestershire.gov.uk/index.cfm?articleid=18196
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22. Each Strategic Nature Area relates to the restoration and enhancement of just one
priority habitat type, even though there is likely to be a mosaic of other habitats
also present within that area. Within the Cotswolds AONB, further guidance on
the appropriate habitat restoration and creation for each landscape character
type is set out in the Board’s Landscape Strategy and Guidelines.8
23. It should be noted that SNAs present only part of the picture. Sites that are of
importance for biodiversity conservation exist both inside and outside the SNAs
(and many of these sites will already be protected by international, national,
regional and local designations). LPAs and their partners should therefore also
consider identifying how objectives set for each SNA will relate to and integrate
with wider biodiversity objectives and policies that are applicable outside of SNAs.
This may include planning for the provision or enhancement of green infrastructure
that links features within and outside of SNAs, and thereby improves the overall
network of habitats.
24. In Oxfordshire (South East Region) a similar concept to SNAs is described as
Conservation Target Areas (CTAs).9 CTAs represent the main locations in
Oxfordshire which can be viewed both as areas of significant ecological constraint
as well as potential areas of ecological opportunity. In order to conform with PPS9,
Local Development Frameworks in Oxfordshire need to:(i) indicate the location of designated sites of importance for biodiversity and
geodiversity, making clear distinctions between the hierarchy of international,
national, regional and locally designated sites;
(ii) Identify any areas or sites for the restoration of priority habitats which contribute
to regional targets, and support this restoration through appropriate policies.
25. The Board considers that in Oxfordshire, Core Strategies should consider
including objectives and policies for the conservation and enhancement of
relevant Conservation Target Areas together with appropriate policies to help
safeguard and enhance the overall biodiversity resource.
26
Similar to the SNA concept, the West Midlands Biodiversity Strategy identified
fourteen Biodiversity Enhancement Areas (BEAs) that were adopted in the
Regional Spatial Strategy. BEAs contain important concentrations of
biodiversity. For example, they cover 25% of the Region but hold 70% of the Sites
of Special Scientific Interest, 86% of the upland and lowland heathland, and 72%
of the unimproved grassland. This makes them ideal places in which to develop an
area based approach for wildlife.
8
http://www.cotswoldsaonb.com/page.asp?pageID=42
Oxfordshire Conservation Target Areas Mapping Project Report (July 2006)
http://portal.oxfordshire.gov.uk/content/publicnet/council_services/environment_planning/countrysid
e/ecology/OCTA-main-report.pdf
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27 To consolidate this area-based approach the West Midlands Biodiversity
Partnership established the Landscapes for Living project. The project has
developed a regional biodiversity map to illustrate potential opportunities for
landscape-scale work across the region, which should include buffering habitats
from adverse impacts, and restoring, re-creating, expanding and linking habitats.
Stage 2 of the Landscapes for Living project, now in the early stages, will result in
biodiversity maps for each of the six West Midlands counties, including
Worcestershire and Warwickshire.
28
There are currently no BEAs defined in the parts of the Cotswolds AONB in
Worcestershire or Warwickshire. However, it is intended that the regional
biodiversity map produced by Landscapes for Living10 will replace the BEA maps
within the Regional Spatial Strategy. More significantly, the Board would anticipate
Bredon Hill and the Cotswold edge to be identified and represented within the
county biodiversity maps for Worcestershire and Warwickshire as important areas
of habitat rich landscape.
29. The Board considers that in Warwickshire and Worcestershire, the local
authorities should consider including objectives and policies for the
conservation and enhancement of areas of conservation value in the
Cotswolds AONB identified through the Living for Landscapes project
together with appropriate policies to help safeguard and enhance the overall
biodiversity resource.
Core Strategy Local Development Document
30
The Board considers that the most appropriate Local Development
Document (LDD) in which to identify SNAs, CTAs and BEAs is the Core
Strategy. The SNAs are of regional strategic significance and should
therefore influence and form part of the Local Planning Authorities overall
strategic vision and objectives.
The SNAs etc., should be identified spatially, within the Core Strategy, on a
Key Diagram or Illustrative Map.
The SNAs etc., should be supported with a clear objective and/or policy that
states that within these areas, specific action will be taken towards meeting
targets for the maintenance, restoration and recreation of priority habitats
and species, and to the linking of habitats to create more coherent units
which are more resilient to climate change.
Site Specific Allocations
31. In order to meet the objectives and/or policies set out for SNAs in the Core
Strategy (see 29), Site Specific Allocations should ensure that the ‘Key Principles’
from PPS 9 have been applied to site selection and that alternatives have been
fully explored with regard to the location, form, type and scale of development
allocated to each specific site.
10
http://www.wmbp.org/landscapesforliving
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32. The Board considers that Site Specific Allocations within SNAs, CTAs and
BEAs should:
(i)
identify how the proposed development might reasonably make a contribution
towards regional biodiversity enhancement targets;
(ii)
ensure that specific allocations do not cause adverse impacts that
compromise the potential of an SNA to achieve regional biodiversity targets
that might be delivered through other mechanisms (e.g. agri-environment or
forestry schemes);
(iii)
ensure that specific allocations do not reduce an SNA’s overall resilience to
climate change; for instance by locating development between two parcels of
priority habitat where it would restrict the migration and dispersal of species
between the two.
Supplementary Planning Documents (SPD)
33. It may be appropriate to supplement site specific allocations with Supplementary
Planning Documents (SPDs) that include guidance on how the LPA expects
development to take account of the biodiversity objectives and targets set for an
SNA. This guidance might be incorporated into a master plan or design guide SPD,
or it might take the form of a specific SPD on biodiversity.
34
Examples of such Supplementary Planning Documents are those adopted by
Wychavon District Council11, and South Gloucestershire Council.12
35
The Board considers that other local planning authorities should examine
the need to produce similar guidance, particularly to provide advice relating
to the submission of planning applications.
Other mechanisms
36. The Board recognises that the achievement of regional targets for the conservation
and enhancement of priority habitats found in the SNAs, CTAs or BEAs cannot rely
solely upon contributions from new development. Other sectors and delivery
mechanisms will also play a very significant role. These will be especially those
associated with agriculture and forestry. In many situations, it is very likely that
conservation organisations, rather than developers, will be key players in the
promotion and implementation of action that leads to biodiversity enhancements.
11
Planning and Wildlife SPD (2008) http://wychavon.whub.org.uk/home/wdc-planning-planningnews-wildlife-spd-2008.pdf
12 Biodiversity and the Planning Process (2005)
http://www.southglos.gov.uk/_Resources/Publications/PTE/05/0200/PTE-05-0078
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37. The following is a list of some of the key mechanisms and funding sources that
may be used to achieve biodiversity enhancement targets.
a.
b.
c.
d.
e.
f.
Aggregates Levy Sustainability Funds13
English Woodland Grant Scheme14
Environmental Stewardship15
Heritage Lottery Fund16
Access to Nature17
Countdown 201018
NOTES
The Cotswolds Conservation Board has the statutory duty19 to pursue the following
two purposes:
a) to conserve and enhance the natural beauty of the AONB; and
b) to increase the understanding and enjoyment of the special qualities of the
AONB.
In fulfilling these roles, the Board shall seek to foster the economic and social wellbeing of people living in the AONB.
The Board is comprised of members appointed by the local authorities, parish
councils and the Secretary of State. The Board, formed in December 2004, is the
only organisation that looks after the AONB as a whole.
The Cotswolds AONB was designated in 1966 and extended in area in 1990. It is
one of 40 Areas of Outstanding Natural Beauty across England and Wales. It is
the largest AONB, covering 790 sq.miles (2038 sq.km). It is a landscape of equal
importance to National Parks such as Snowdonia and the Lake District.
For further information contact:
Malcolm Watt,
Planning Officer,
Cotswolds Conservation Board
Fosseway
Northleach
Glos GL54 3JH
Tel: 01451 862004 Fax: 01451 862001
Email: malcolm.watt@cotswoldsaonb.org.uk.
13
Website: www.cotswoldsaonb.org.uk
http://www.sustainableaggregates.com/
http://www.defra.gov.uk/erdp/schemes/wgs/default.htm
15 http://www.defra.gov.uk/erdp/schemes/es/default.htm
16 http://www.hlf.org.uk/english
17 http://www.naturalengland.org.uk/leisure/grants-funding/
18 http://www.english-nature.org.uk/About/countdown.htm
19 Section 87. Countryside and Rights of Way Act 2000
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