Arlen Hill Draft Local Plan

45 Oxford Street
Manchester

While we acknowledge the importance of adapting planning strategies to evolving national and regional policies, we believe that the revisions in the National Planning Policy Framework (NPPF) and the City Plan must explicitly incorporate robust environmental considerations. Our primary concern is the need for a comprehensive integration of policies and strategies that actively prioritize biodiversity protection, sustainable land use, and climate change mitigation.

The recent declaration of a climate emergency in 2019 underscores the urgency of addressing environmental challenges. We believe that the Local Plan review must reflect a strategic and coherent response to the climate emergency, aligning with the newly adopted priorities outlined in the 'Corporate Strategy 2018 – 2022.' Our disagreement stems from the perception that the provided content lacks a clear and enforceable commitment to mitigating the impacts of climate change, promoting sustainable practices, and safeguarding the Borough's natural assets.

As a Forest Protection Authority, we advocate for the integration of policies that explicitly safeguard our woodlands, green spaces, and natural habitats. The importance of green infrastructure and the preservation of ecological corridors must be highlighted in the revised Local Plan, ensuring a harmonious balance between urban development and environmental conservation.

Furthermore, considering the impact of the COVID-19 pandemic, we urge the council to view the recovery and rebuilding process as an opportunity to instill resilience and sustainability in the local community. The inclusion of nature-based solutions, sustainable land management, and green infrastructure in the Local Plan will not only contribute to biodiversity conservation but also enhance the overall well-being of residents.

Our primary concern revolves around the emphasis on environmental sustainability and biodiversity protection within the outlined strategic objectives. While we acknowledge the relevance of housing, economy, and community well-being, we firmly believe that the strategic objectives should explicitly prioritise the preservation and enhancement of natural assets, including woodlands, green spaces, and ecological corridors.

The strategic objectives, as presented, lack a distinct focus on responding comprehensively to the climate emergency, which is a critical consideration in contemporary urban planning. We strongly advocate for the inclusion of strategic policies that actively address climate change, promote sustainable land use, and foster the integration of green infrastructure within the Borough.

Moreover, the absence of specific strategic objectives centered on green spaces, urban forestry, and biodiversity preservation is notable. We propose that the Local Plan should explicitly recognise the role of forests and green areas in mitigating the impacts of climate change, enhancing air and water quality, and providing recreational spaces for the community.

As a Forest Protection Authority, our mission aligns with ensuring the sustainable management of forests and safeguarding the biodiversity they support. We encourage the integration of strategic policies that emphasise the importance of green infrastructure, habitat preservation, and sustainable land management practices. This would contribute not only to the ecological resilience of Arlen Hill but also to the overall well-being of its residents.

Our concern revolves around the need for a more explicit commitment to preserving and expanding green infrastructure, which is essential for ecological balance, biodiversity conservation, and the overall well-being of Arlen Hill's residents. The strategic objective should explicitly recognise the irreplaceable role of forests in mitigating climate change, improving air quality, and providing essential habitat for wildlife.

We recommend a strengthened emphasis on the protection and enhancement of Arlen Hill's network of green infrastructure, ensuring that it aligns with broader environmental goals, including the safeguarding of forests. Specific policies addressing the sustainable management of green spaces, the integration of urban forestry, and measures to protect and enhance biodiversity should be integral to the strategic approach.

Moreover, the promotion of brownfield redevelopment is commendable, and we suggest incorporating policies that prioritise greenfield development only as a last resort, ensuring that existing green spaces and woodlands are safeguarded. The Council's commitment to a design-led approach is appreciated, and we propose an explicit integration of green design principles that contribute to the overall resilience and ecological health of the Borough.

Lastly, active community engagement should extend to matters related to green infrastructure, with residents and community groups playing a significant role in shaping the future of Arlen Hill's natural spaces. The Council should consider measures to involve the community in local conservation efforts, ensuring a sense of ownership and shared responsibility.

Our primary concern lies in the spatial strategy options, specifically the M32 flyover options A and B within character areas 1 & 2. As a Forest Protection Authority, we emphasize the critical importance of preserving and safeguarding existing green spaces, including woodlands and forests, which contribute significantly to biodiversity, air quality, and the overall ecological balance of the Borough.

The M32 flyover options raise concerns about potential disturbances to established green corridors and wildlife habitats. We urge the Council to thoroughly assess the ecological implications of these options and consider alternatives that minimize the impact on existing natural areas. Additionally, it is crucial to ensure that the spatial strategy aligns with broader environmental goals, including the protection of Arlen Hill's green infrastructure.

Furthermore, we recommend a more robust integration of green design principles within the spatial strategy. This includes measures to incorporate urban forestry, green buffers, and the strategic placement of developments to minimize disruption to existing ecosystems. By doing so, the Council can demonstrate a genuine commitment to sustainable and ecologically responsible development.

In the pursuit of Good Growth, it is essential to strike a balance between accommodating development needs and preserving the natural assets that contribute to the overall well-being of residents. We encourage the Council to explore alternative spatial strategy options that prioritise the protection of green spaces and woodlands, contributing to a more resilient and environmentally conscious Borough.

While recognising the challenges associated with inequality and deprivation, we believe it is crucial to extend the focus beyond purely social and economic factors. Environmental inequality, often experienced by marginalised communities, must also be considered as part of the broader approach to enhancing the quality of life for all residents.

Green spaces and woodlands play a pivotal role in contributing to the overall well-being of communities. Unfortunately, certain localities may face disparities in access to these natural resources, which can have implications for physical and mental health. As a Forest Protection Authority, we advocate for an inclusive approach that ensures equitable distribution of green spaces and forests throughout Arlen Hill.

We encourage the Council to incorporate green infrastructure planning into strategies addressing social and economic disparities. By prioritising the creation and enhancement of accessible green spaces in underserved areas, the Borough can contribute to a more equitable distribution of environmental benefits. This approach aligns with the principles of environmental justice, promoting equal access to the positive impacts of nature.

Subject: Forest Protection Authority's Perspectives on Land Use Efficiency in Arlen Hill

Dear [Local Planning Authority],

We appreciate the comprehensive approach outlined in the Local Plan to address the challenges and opportunities associated with growth in Arlen Hill. While we acknowledge the need for efficient land use, we would like to express our perspective as a Forest Protection Authority, emphasizing the importance of maintaining a balance that safeguards the Borough's natural landscapes.

The concept of making the best use of land through efficient and flexible development aligns with the broader goals of sustainability and urban planning. However, we would like to stress the significance of prioritizing brownfield redevelopment as outlined in the policy. We fully support the emphasis on redeveloping brownfield or previously developed land before considering greenfield areas.

Preserving Arlen Hill's green and open spaces is essential for ecological diversity, community well-being, and the overall health of the environment. As a Forest Protection Authority, we propose further clarification on the criteria and guidelines for appropriately located higher density and mixed-use developments. Ensuring that these developments positively respond to and enhance the character of the Borough's town centers and neighborhoods is crucial for maintaining a sustainable and vibrant community.

We recommend incorporating specific measures to protect and enhance existing green infrastructure, including woodlands and natural habitats. Brownfield redevelopment should be approached with a careful consideration of the ecological value of the land, and efforts should be made to integrate green spaces within the developments wherever possible.

We would like to express our perspective on the need for further clarity and specificity regarding the integration of green spaces and woodland areas within the design-led approach. The Arlen Hill Characterisation Study (2019) is a commendable step in defining the Borough's features, but we believe there is an opportunity to strengthen the language within the Local Plan to explicitly safeguard and incorporate natural assets.

Green infrastructure, including woodlands and open spaces, plays a vital role in enhancing the quality of life for residents, supporting biodiversity, and promoting ecological balance. We recommend that the Local Plan explicitly includes guidelines for the integration of green spaces within new developments, ensuring they complement and augment the local character.

Our recommendation is to enhance the language within the Local Plan to more explicitly outline strategies for safeguarding and restoring green spaces, such as woodlands, and ensuring their effective integration into the urban fabric. Specific policies could include measures to protect wildlife corridors, enhance tree canopy coverage, and encourage the use of sustainable urban drainage systems (SuDS) to manage water runoff effectively.

We recommend strengthening the language to explicitly emphasise the protection of natural habitats from the potential adverse effects of external lighting. The policy should encourage measures that minimise disruptions to ecosystems, particularly during critical periods such as nesting seasons for local fauna.

The policy could provide more explicit guidance on mitigation measures for adverse impacts of light pollution. This may include specifying the types of measures considered appropriate and effective in preserving the natural darkness of the environment.

Consider incorporating elements of dark sky-friendly design principles into the policy. This would involve promoting outdoor lighting that minimises skyglow, glare, and light trespass, contributing to the preservation of the natural nighttime environment.

Inclusive biodiversity planning: Promote inclusive design principles that consider biodiversity as an integral part of the amenity areas. This includes ensuring that any landscaping or changes to garden land contribute positively to the local flora and fauna, creating resilient urban ecosystems.

Monitoring and evaluation: Establish mechanisms for monitoring the impact of garden land and amenity area policies on biodiversity. This could involve periodic assessments to ensure that the preservation efforts align with broader environmental and ecological goals.

We have reviewed the section of the Arlen Hill Local Plan that addresses the preservation and enhancement of the historic environment, and we wish to provide our perspective, particularly focusing on how these policies intersect with forest protection and broader environmental considerations:

Biodiversity and heritage integration: While we appreciate the commitment to preserving the historic environment, we recommend explicitly integrating biodiversity considerations into heritage conservation policies. Encourage development proposals to explore opportunities for enhancing biodiversity within the context of historic sites, fostering a holistic approach to environmental conservation.
Green Heritage Corridors:

Consider recognising and preserving "green heritage corridors" that may exist within the historic environment. These could be areas with significant ecological value that complement the historical significance of the site, contributing to both cultural and environmental heritage.

We would like to provide feedback on certain aspects that we believe warrant reconsideration:

We recommend incorporating provisions for integrating green infrastructure within Conservation Areas. This could include measures to enhance green spaces, encourage tree planting, and promote biodiversity while aligning with the conservation objectives.

Strengthen the policy by explicitly addressing biodiversity considerations within and around Conservation Areas. Encourage the preservation of habitats, protection of wildlife corridors, and the use of native plant species to support the ecological balance of these areas.

Consider explicitly incorporating sustainable design principles within the guidelines for new developments. This could involve promoting energy-efficient design, the use of eco-friendly materials, and the integration of sustainable technologies without compromising the historic character.

Enhance community engagement strategies specific to Conservation Areas. Involve local communities in identifying and preserving the unique features of these areas, fostering a sense of shared responsibility for their conservation.

Promote adaptive reuse as a primary strategy for preserving the special character of Conservation Areas. This approach allows for the conservation of historic structures while accommodating contemporary needs, contributing to sustainable development.

Introduce requirements for ecological impact assessments as part of the planning process for the redevelopment of sites within Conservation Areas. This will ensure a comprehensive understanding of the environmental implications of proposed developments.

Strengthen measures to preserve existing trees within Conservation Areas. Include guidelines for the protection of mature trees, considering them as integral components of the historic and ecological fabric of these areas.

Establish a robust monitoring framework for Conservation Areas, including periodic assessments of the impact of development on their character. Implement adaptive management strategies based on monitoring outcomes to address evolving conservation needs.

We recommend incorporating more explicit policies that outline measures to safeguard critical ecosystems, including woodlands and natural habitats. Green infrastructure, particularly woodlands, plays a pivotal role in supporting biodiversity, mitigating climate change impacts, and fostering ecological resilience. Therefore, specific policies aimed at protecting and enhancing these natural assets should be articulated within the document.

Moreover, we propose the inclusion of guidelines for sustainable land management practices that ensure the long-term health of existing green spaces. This could involve measures to prevent soil erosion, protect water quality in waterways, and encourage the adoption of sustainable landscaping practices. A commitment to preserving biodiversity and habitat connectivity should also be clearly stated within the Local Plan.

To ensure the enduring protection of open spaces, we suggest explicit policies emphasizing the preservation of natural habitats within these areas. The Local Plan should articulate clear criteria for identifying and safeguarding biodiversity hotspots, crucial wildlife corridors, and ecologically sensitive zones within open spaces. This will contribute to the conservation of local flora and fauna and enhance the overall resilience of the ecological network.

Additionally, the Local Plan could benefit from more stringent guidelines for developments within or adjacent to open spaces. Specific criteria should be outlined to assess the impact of new developments on the environmental function of open spaces, with a focus on avoiding any degradation of natural habitats. Proposals should be evaluated based on their potential contributions to nature conservation, such as creating buffer zones, enhancing green corridors, and supporting local biodiversity.

Regarding allotments and community gardens, while the Local Plan rightly seeks to protect these spaces, we suggest incorporating specific measures to ensure their long-term viability. Proposals for major housing developments should not only encourage but mandate the provision of space for community gardening. The plan could benefit from clear guidelines on the size, accessibility, and amenities within these spaces to maximise their social, educational, and environmental benefits. Additionally, when existing provision is impacted by redevelopment, stronger language should be employed to ensure the seamless retention or re-provision of these valuable community assets.

Geodiversity is a critical aspect of Arlen Hill's natural heritage, and the Local Plan rightly acknowledges the importance of protecting these assets. However, to enhance the effectiveness of geodiversity conservation, we recommend establishing a comprehensive strategy for the identification, preservation, and promotion of geodiversity across the borough. This could involve a systematic survey of geodiversity assets, leading to the designation of additional Regionally Important Geological Sites. Clear criteria for the positive contribution of development proposals to geodiversity protection should also be outlined, ensuring that projects go beyond mere compliance and actively contribute to enhancing this aspect of the borough's natural environment.

We recommend enhancing the specificity and ambition of the plan's targets. Consider setting clear and quantifiable goals for reducing greenhouse gas emissions, both in the operation stage and during the construction phase. This could include setting milestones for achieving specific percentages of emission reduction over time, aligning with national and regional targets.

Moreover, the plan should explicitly address the integration of nature-based solutions and sustainable land-use practices in achieving carbon neutrality. Green infrastructure, such as urban forests and natural habitats, can play a crucial role in sequestering carbon and enhancing overall ecological resilience.

To enhance transparency and accountability, consider including a clear mechanism for ongoing monitoring and reporting on air quality parameters. This can include periodic assessments of the actual air quality impact of implemented developments and the effectiveness of any mitigation measures. Public access to this information will foster community engagement and ensure that the Local Plan's objectives are met over time.

Regarding Air Quality Assessments, we recommend specifying a standardised methodology for conducting these assessments, ensuring consistency and comparability across different proposals. Providing detailed guidance on the required scope, methodology, and parameters for these assessments will facilitate a more straightforward and effective evaluation process.

The plan appropriately highlights a sequential approach to new development locations and directs development away from flood-prone areas. However, we recommend further emphasis on green infrastructure solutions for flood risk reduction, such as the preservation and enhancement of natural floodplains and the creation of buffer zones along watercourses.

The Flood Risk Assessment requirement should explicitly include an evaluation of climate change impacts on flood risk, ensuring that developments are resilient to future challenges.

While the plan acknowledges the importance of SuDS, we recommend incorporating a stronger mandate for their implementation in all applicable developments, regardless of their size. The plan should explicitly specify that SuDS must be an integral part of the design process, promoting natural drainage solutions.
Permeable surfaces should be actively encouraged and, where feasible, mandated to promote groundwater recharge and reduce surface water runoff.

The plan's commitment to protecting water quality is commendable. We suggest strengthening this commitment by including measures to prevent contamination from construction activities and encouraging sustainable landscaping practices that minimise the use of harmful chemicals.
Regarding wastewater and water supply, the plan should consider potential impacts on local water sources and ecosystems, especially in areas with Source Protection Zones. Clear guidelines on protecting groundwater quality in such zones would strengthen environmental safeguards.

We believe there is room for refinement to enhance the plan's effectiveness and ensure a more robust approach to environmental protection.

Contaminated Land: We recommend incorporating a stronger focus on sustainable and nature-based solutions for remediation wherever applicable. Green and blue infrastructure, such as wetlands and vegetative cover, can contribute significantly to natural attenuation and the long-term improvement of contaminated sites. Consideration should be given to incentivising developers to prioritise brownfield sites for redevelopment, contributing to urban regeneration while minimising pressure on greenfield areas.

Hazardous substances: We suggest including a specific requirement for developers to explore alternative, less hazardous materials or technologies wherever feasible. This approach aligns with broader environmental sustainability goals. The plan could benefit from providing clear guidance on emergency response plans for hazardous substance incidents, ensuring that local authorities and emergency services are adequately prepared to manage any unforeseen events.

Integration with Green Infrastructure: To complement the contaminated land and hazardous substances policies, we recommend encouraging the integration of green infrastructure elements in the design and planning of developments. Nature-based solutions, such as green roofs and permeable surfaces, can contribute to the overall environmental health of an area and mitigate the impacts of contamination.

Public Awareness and Participation: The plan should promote transparency and public awareness regarding contaminated land and hazardous substances. Including provisions for community engagement in the decision-making process and information dissemination would empower local residents and foster a sense of environmental responsibility.

Climate-responsive design: Integrate climate-responsive design principles to ensure the corridor is resilient to the impacts of climate change. This may include measures to address heat island effects, stormwater management, and energy-efficient urban design.

Community engagement and inclusivity: Strengthen community engagement processes to involve local residents in shaping the development of the central growth corridor. Consider incorporating the diverse needs and perspectives of the community to foster a sense of ownership and inclusivity.