Minerals Plan: Key Issues & Options

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Comment Information

Comment Information
Document Section Derby & Derbyshire Minerals Core Strategy: Key Issues & Options Part One: Background Information Chapter 3: A General Portrait of Derbyshire the Natural Heritage section [List all comments on this document part]
Comment ID /3997185/2
Respondent Tom French - Derbyshire County… [List all comments by this respondent]
Response Date 18 Aug 2010
Comment
This section offers a fantastic opportunity to paint a real, insightful portrait of Derbyshire, which will be an essential component of spatial planning. Unfortunately, however, this section appears to fall well short. For example, in relation to the Natural Heritage section, only a very limited amount of information is presented in relation to ecological interests, and what is present lacks the detail and the analysis to usefully inform the emerging plan, or the consideration of the options.



As an illustration, a small amount of data is presented in relation to the number of designated sites within the plan area (some of this is wrong, see below) - but listing the number of sites covered by each designation only gives part of the picture. To extend this metaphor still further, just as a portrait of a person would be unrecognisable if we only knew how many eyes, ears noses and mouths they had - but not how they where composed, how they related to each other or the context in which they sat - so the spatial portrait of the natural environment needs to explore the data further to give a meaningful picture. In relation to SSSIs, for example:



· The existing document states that there are 87 SSSIs within the plan area (as well as three SACs, 1 NNR etc), and that the county "contains significant areas of ecological importance" HOWEVER

· Taking the geographical area of the county (including the Peak park area inside Derbyshire), c 11% of the county area is designated as a SSSI. This compares extremely well with regional and national averages, for which I believe the national average percentage SSSI cover is c 7.5%, whilst the regional average is rather lower at c4.5%. BUT;

· Outside of the Peak Park, i.e. the area covered by the emerging MDF, only 0.75% of the county area is covered by SSSI designations. This is an extremely small proportion of the county land area - and probably the lowest proportion (with the possible exception of unitary city areas) in the region. Conversely;

· Within the peak park area of the county, c 32% of the land area is designated as SSSI, and a large proportion of this is covered by European level designations



This sort of analysis is crucial for the spatial portrait, as it presumably has numerous consequences for the MDF:

· I would suggest this lends weight to the proposal to reduce mineral consumption within the Peak Park...

· Without raising the significant likelihood of affecting designated sites in the rest of Derbyshire

· Further analysis could explore the spatial distribution of SSSIs within the plan area - where are the SSSIs in relation to the mineral resources? They certainly aren't evenly distributed within the county



Other pieces of analysis might also prove useful - for example, if there are 87 SSSIs within the plan area, which cover (by our landscape technician's calculations) c 1300Ha, the average SSSI size is less than 15Ha. Yet if you exclude a small number of untypically large SSSIs - Calke Park (71Ha), Ogston reservoir (95Ha), Shining Cliff woods (119Ha), Via Gellia Woods (c137Ha in our area), Kedleston Park (93Ha), for example, which collectively account for 500Ha, the remaining 82 sites cover just 800Ha - meaning that on average, SSSIs in lowland derbyshire are both quite small (less than 10Ha), and typically disconnected from other sites.



Again, this might have policy implications:



· If Derbyshire (our authority area) is under resourced in terms of land area covered by statutory designations, should the MDF ensure the protection of existing sites, and moreover, as a spatial plan, seek opportunities to buffer, enhance and extend the amount of biodiversity interest, and connect existing sites?

· Accepting that in some ways, parts of the county are lacking significant interest, but in others, the interest may have been overlooked when the SSSI assessments were undertaken (we know this was the case as effort was focussed on the Peak Park), does this make our locally designated sites even more valuable?



Other data might also be of interest - for example, Ancient Woodland mapping has been assessed by Natural England, and suggests that Derbyshire contains one of the five biggest areas of interconnected ancient woodland in the country - but this is focussed within an area in and around the Derwent Valley, which is unlikely (?) to suffer significant mineral extraction pressure.



I would also question whether the Regional Biodiversity strategy offers the most robust evidence base for areas requiring conservation or enhancement - this study is now a few years out of date, and may be (at least partially) replaced by regional GI mapping, or a Biodiversity Opportunity Mapping tool, which is being developed by Natural England through the East Midlands Biodiversity Forum, and which is anticipated imminently. Certainly, the data presented in paragraph 3.16 appears misleading - it is counter intuitive to think that the 'most important regional resources for biodiversity' are Sherwood, Derbyshire Peak Fringe/Lower Derwent and Charnwood Forest. Even within the county context I would suggest this is incorrect.



In relation to data, I suspect that some of the figures presented for numbers of designated sites may be incorrect. Although paragraph 3.17 suggests there are 3 SACs within our area, there are actually 5, as we have a small amount of the South Pennine Moors SAC (Goyt Valley, west of Burbage) and the Peak District Dales SAC (Wye Valley near Buxton) in our area, outside of the PDNPA. The Goyt Valley SSSI is also designated as an SPA. Regardless of whether there are three or 5 Natura 2000 suite sites within our area, we must also be mindful of the fact that in the development of our plans, policies and procedures, we need to consider all such sites - see Regulation 102 of The Conservation of Habitats and Species Regulations 2010 (replaces the 1994 Habitats Regulations), and hopefully, any Habitats regulations Assessment (Appropriate Assessment) work undertaken for the SA/SEA.