West Suffolk Local Plan (Regulation 18) Issues and Options October 2020

Part 2 - local issues

Part 2 - 8. Natural and historic environment

Natural environment

8.1. The rural nature of West Suffolk contributes to the high quality, diverse and locally distinctive natural environment. Large parts of the district are protected by statutory designations of international and national importance as well as locally protected sites of biodiversity or geological value and soils. In addition, there are also many priority habitats, urban and green spaces, and waterbodies that support overall ecological connectivity in the district.

8.2. West Suffolk has distinct landscape character areas including The Brecks, The Fens, The Claylands and East Anglian chalk. The county wide Landscape Character Assessment provides information to promote wider understanding of the landscape of Suffolk at a more detailed scale and help to inform the design of new development. Within West Suffolk some landscapes have particular value locally such as Breckland, and the Stour Valley. Other areas, for example around Bury St Edmunds, have retained their special landscape area designation. However, for many residents the natural environment is best represented by the trees close to their homes, and the open spaces, parks and woodlands to which they have access.

Brandon Country Park (2020)
Brandon Country Park (2020)

Implications of the sustainability appraisal (SA) scoping report information

8.3. The SA scoping report identifies the following key sustainability issues:

  • Any new development must not undermine the integrity of designated sites and the ecological network should be supported and enhanced.
  • Future development should seek to maximise opportunities for biodiversity net gain.
  • New development and settlement expansion should not impact upon the varied and rich landscape character and settlement identities.
  • Development should seek to enhance green infrastructure networks that maximise the benefits of landscape features but minimise impacts on the most sensitive landscape areas.
  • Development will need to consider its impacts on natural resources and sustainable waste management.

Issues for the local plan

Protection of biodiversity

8.4. Statutorily protected habitats and species are given a high level of protection by law, and local authorities have a duty to consider the effects of their decisions on nature conservation. Within West Suffolk, Breckland Special Protection Area is a particularly sensitive Natura 2000 site. Local plan policies include measures to avoid impacts from built development on the protected birds, the stone curlew, woodlark and nightjar for which it is important. The measures are defined by strategic buffers and the evidence suggests these should be retained.

8.5. In addition, there is growing evidence for concern about recreational pressure. A visitor survey of recreation sites in Breckland SPA found that many visitors to the forest are local residents who are using Thetford Forest as their local greenspace, and whilst currently visitor levels are relatively low in comparison with other SPA heathland sites, new development adjacent to the SPA may result in increased access and a precautionary approach is required. Natural England has advised that it is necessary to consider cumulative recreational effects.

8.6. There is also a network of county wildlife sites across the district and in Haverhill and Bury St Edmunds local wildlife sites have been identified.

Net gain in biodiversity

8.7. In addition to the protection and enhancement of biodiversity the NPPF encourages local planning authorities to pursue opportunities for securing measurable net gains for biodiversity. Biodiversity Net Gain (BNG) is an approach to development that leaves biodiversity in a better state than before. It encourages developers to provide an increase in appropriate natural habitat and ecological features. The aim is that the current loss of biodiversity through development will be halted and ecological networks can be restored.

Protection of landscapes and landscape features

8.8. There are no nationally designated landscapes within West Suffolk, however the NPPF recognises the intrinsic character and beauty of the countryside and the wider benefits from natural capital and ecosystem services.

8.9. Across West Suffolk special landscape areas, originally identified by Suffolk County Council, have not been uniformly retained throughout the district. Instead emphasis has been placed on the assessment of the effects of development on landscape character. The Brecks and the River Stour Valley, which are the focus of landscape scale projects, have been identified as having particular sensitivity to change. However, there are other parts of the district, such as some river valleys, which are not identified but are equally sensitive.

8.10. Trees have a significant role to play in both rural and urban areas and have many benefits, including mitigating the effects of climate change and improving air quality. The most important trees can be protected by tree preservation orders where necessary. However, despite this, development pressures continue to lead to tree losses, and there are additional long term threats to existing trees from pests, disease and climate change.

8.11. Through the preparation of the local plan we will need to consider how policies can best ensure the protection of landscapes, trees and other natural features. 

Provision of green infrastructure to support development

8.12. Green infrastructure (GI) is a network of multi-functional green spaces and other features, urban and rural, which can deliver quality of life and environmental benefits for communities. The NPPF highlights the many benefits that green infrastructure can provide and that local plans should help to deliver, for example through supporting healthy lifestyles, managing the effects of climate change, and opportunities to improve air quality issues.

8.13. The St Edmundsbury Green Infrastructure Strategy (2009) and the Accessible Natural Greenspace Strategy for the former Forest Heath area (2017) identify existing GI features and provide opportunities for new GI within the two areas. However, a new green infrastructure strategy for the whole district will be developed to support the West Suffolk Local Plan.

Protecting and enhancing the quality of the district's natural resources

8.14. One of the impacts of climate change that affects our area is the scarcity of water. West Suffolk falls within the Anglian River Basin District and the Anglian River Basin Management Plan provides a framework for protecting and enhancing the benefits provided by the water environment. The document is prepared by water companies to ensure that water supply will meet demand in the future. A new WRMP being produced and emerging information predicts that the plan area will be in a water deficit by 2045 with planned strategic actions to address water pressures.

8.15. Across the district air quality is considered generally good and continues to show long-term improvement at monitored locations throughout the area. However, there are three designated Air Quality Management Areas (AQMA) in West Suffolk, located in Newmarket, Great Barton and Bury St Edmunds.

8.16. The NPPF is clear that the focus of planning policies and decisions should be on whether proposed development is an acceptable use of land, rather than the control of processes or emissions (where these are subject to separate pollution control regimes). Planning authorities should therefore work on the assumption that the relevant pollution control regime will be properly applied and enforced. However, the planning system plays an important role in determining the location of development which may give rise to pollution, and in ensuring that other developments are, as far as possible, not affected by major existing, or potential sources of pollution.

8.17. An updated water cycle study and strategic flood risk assessment will be prepared as evidence to inform the local plan. This will explore and update capacity in relation to wastewater treatment capacity and outline measures to support an updated WRMP.

Implications of the sustainability appraisal (SA) scoping report information

8.18. The SA scoping report identifies the following key sustainability issues for natural resources:

  • Fluvial flood risk affects a number of settlement areas across the district
  • Surface water flood risk is more wide spread across the district and affects most settlement areas. It will be important for new development to ensure that measures are taken to reduce surface water flood risk and manage the effects of surface water run-off
  • Local plan policies will need to support the strategic actions of the Anglian Water Resource Management Plan to ensure that predicted future water deficits are not exacerbated
  • The high-quality and 'best and most versatile' agricultural land is likely to face increasing pressures from development. Settlement expansion options in the south are likely to lead to the loss of higher-quality soils.
  • There are opportunities to deliver some new development on brownfield sites within the district, though this is a finite resource and can be challenging to fully unlock.
  • There are mineral-related facilities and activities and waste sites safeguarded in the district. Many settlement areas also lie within a minerals consultation area. Development will need to consider its impacts on natural resources and sustainable waste management.
  • There are three designated AQMAs in the district which are considered particularly sensitive to growth and increased traffic congestion.
  • Market towns are also identified as key locations which are sensitive to growth in terms of the associated pressures on air quality.
  • Development will need to ensure it does not undermine continued improvements to air quality across the district and will locate development to minimise the impact of noise pollution.

Issues for the local plan

  • Fluvial and surface water flooding management
  • Maintaining water supply and quality
  • Protecting best and most versatile land and reuse of brownfield land
  • Air quality improvements and minimising noise effects and light pollution.

8.19. Currently in West Suffolk planning policies on protection and management of natural resources, including soil, air and water, include both overarching strategic policies and detailed policies in the JDMP. These policies aim to conserve and where possible enhance air quality, soil quality and local distinctiveness, and water quality and availability. Policies also require proposals for development to consider minimising the use of resources and making improvements where necessary to reduce pollution.

8.20. Making the best use of natural resources and preventing soil, air, noise and water pollution, will contribute to the challenge of tackling climate change and avoid significant adverse impacts on health and quality of life.

Historic environment

8.21. West Suffolk has a high quality, nationally important, unique and diverse historic environment which contributes significantly to its sense of place. There are many features of architectural, archaeological and historic interest which are a key element of the distinctive character and cultural identity of the district's towns, villages and countryside. These features or historic assets include over 3,500 Listed Buildings and structures, nearly 50 Conservation Areas, four Historic Parks and Gardens and numerous buildings and structures of local interest, as well as over 100 Scheduled Ancient Monuments and many other archaeological sites which are identified in the Suffolk Historic Environment Record. They all contribute to both the rural and urban character of the district, whilst also being important for their tourism, education and research value.

8.22. These are all finite resources that could easily be damaged or destroyed by development unless protected by appropriate planning policies.

Implications of the sustainability appraisal (SA) scoping report information

8.23. The SA scoping report identifies the following key issues:

  • There is a rich variety and distribution of designated and non-designated heritage assets present within the district; the significance and setting of which should be considered in, and positively impacted upon by, new development.
  • Designated and non-designated heritage assets are likely to continue to be afforded protection through the NPPF. However, the local plan provides opportunities to better identify and reflect the significance of locally designated and non-designated heritage assets and heritage settings.
  • There are 23 designated heritage assets identified by Historic England as being at risk. Development that can reduce this number will support the integrity of the historic environment in West Suffolk.
  • Heritage assets at risk could potentially deteriorate further without intervention or as a result of inappropriate development.

Historic core of Clare (2011)

Issues for the local plan

  • Protect, conserve and enhance heritage assets, including their setting and significance, and contribute to the maintenance and enhancement of historic character through the design, layout and setting of new development.
  • Ensure that, where possible, development contributes to improved public understanding of assets and their settings.

8.24. Current planning policies on the historic environment in West Suffolk include both overarching strategic policies and detailed policies in the JDMP. These policies aim to protect, conserve and where possible enhance the historic environment and require proposals for development to consider local distinctiveness and the sensitivity to change of historic assets and their settings. National policy has not changed substantially in this area of planning policy since the JDMP was adopted in 2015, and we have used these existing policies to consider the SA issues set out above. JDPM policies cover the following areas, listed buildings, local heritage assets and buildings protected by an Article 4 Direction, conservation areas, new uses for historic buildings, parks and gardens of special historic or design interest, archaeology and enabling development. The next consultation stage will provide opportunity to comment on detailed policies related to heritage.