Object

Representation ID: 174

Received: 10/10/2019

Respondent: Mick George

Legally compliant? Yes

Sound? No

Duty to co-operate? No

MGL objects to Policy SP2 – Biodiversity-Led Restoration and in particular part 1 of the policy which does not clarify sufficiently the potential conflict with the type of restoration sought and the need to preserve the long term potential of best and most versatile soils. Although there is a useful and welcome mention in paragraph 3.14 of the recognition that agricultural afteruses might be compatible with biodiversity objectives, there is no discussion of the potential conflicts that occur with other environmental objectives or of the realities of mineral working in the justification text. For example, in paragraphs 3.23-3.25 there is a list of priority habitats but no recognition of how this might fit in with safeguarding BMV soils. Moreover, it is expected in the creation of open water areas will be minimised (paragraph 3.26) although in the absence of fill material with which to create land areas this will not be possible to achieve.
2. The confusion over policy objectives is also apparent in paragraph 5.130 of the Plan where it is said, “Where the proposed after use is to be one which requires little or no soil, e.g. a lake or a nature reserve requiring impoverished soil resources, it would be better for soils to be removed from site and used beneficially elsewhere.” This requirement may not be a wise choice since surplus soils are often needed as fill for marginal lake habitats in order to create the biodiversity sought by national and local policy and to reduce areas of open water.
3. Furthermore, any reference to “soils” should make clear this relates to “topsoil”. It would appear irrational to export subsoil materials offsite.
4. MGL is seeking the acknowledgement that agricultural afteruses are still important for the best soils for inclusion in the policy to aid clarification of potentially conflicting objectives.
5. The reason for the proposed changes is that the policy is not justified or effective.