This Strategy sets out the vision for 2020 to 2025 to help Sutton work towards the Council's declared Climate and Ecological Emergency.
It identifies habitats and species in the Borough that are of national, regional and local importance and outlines a plan of action for their protection, management and enhancement.
The purpose of the strategy
Sutton’s Biodiversity Strategy is a plan of action to ensure that plants, animals and ecosystems are conserved, protected and enhanced and that progress is tracked, using measurable targets.
FIve key habitats are presented through the Strategy:
- Woodland and Scrub
- Chalk Grasslands
- Rivers and Wetlands
- Parks and Green Spaces
- Green Infrastructure and Biodiversity Net Gain
An explanation of Sutton's Biodiversity Strategy: 2020-2025
Biodiversity does not stop at the borough boundary, so although this strategy concentrates on what Sutton will do to deliver for local wildlife, it clearly acknowledges through Policy Bd6 that: "The Council will proactively work with the GLA to fulfil regional targets and national organisations (such as Natural England and DEFRA) in the delivery of landscape scale work, such as the Nature Recovery Network and mandated Biodiversity Net Gain (BNG)".
This is a living plan, so from time to time it will be necessary to amend and update sections. This is where YOU can influence the future direction of the London Borough of Sutton, to ensure that it remains great for wildlife and people.
If you have comments on the Biodiversity Strategy, please contact the Biodiversity Team.
Whilst most of the actions are for the Council to undertake, in partnership with other key stakeholders, such as the South East Rivers Trust (SERT), it is vital that all residents help local biodiversity.
The Strategy outlines ways in which people can help wildlife. One of the most important is through supporting local conservation organisations. The London Borough of Sutton has been supporting and facilitating the work of Sutton Nature Conservation Volunteers (SNCV) for over 30 years, to deliver 'Nature on you Doorstep'. The SNCV website holds some really useful information on what residents can do to help local wildlife, particularly through wildlife gardening.
Submitting wildlife sightings from within Sutton to London's Biological Record Centre, Greenspace Information for Greater London also helps provide more information on our species, their abundance and distribution. You can download a recording sheet from them.
The Biodiversity Strategy is also essential reading for developers wishing to make planning applications within the London Borough of Sutton, as it clarifies and expands on planning policies and guidance as to how Sutton will assess planning applications, especially Biodiversity Net Gain.
Biodiversity Net Gain
One of the most significant aspects of this Biodiversity Strategy is that it provides further information and guidance on the delivery of of No Net Loss and Biodiversity Net Gain through planning applications.
Policy 26 of the Local Plan 2018-2031 states that: "The council will protect and enhance Sites of Importance for Nature Conservation, Green Corridors and biodiversity. It will ensure the restoration of Beddington Farmlands is completed to the agreed quality and
implement its Biodiversity Action Plan and agri-environment schemes. Major new development should result in no net loss in biodiversity value, as assessed against the DEFRA biodiversity offsetting metric, the Environment Bank Biodiversity Impact Calculator or any metric which the council subsequently adopts formally. New development should incorporate opportunities to enhance biodiversity, wherever possible."
The adopted Building a Sustainable Sutton: Technical Guidance Note for Developers Section 2 'Biodiversity Accounting', outlines in more detail how the Council will deliver No Net Loss and Biodiversity Net Gain.
It also clearly states that "Biodiversity Accounting will also be applied, judiciously, to those applications of medium and possibly, small size that suggest the loss or impact on an amount of biodiversity, habitat or green space, including back garden land and the above plans, to ensure that, as far as possible, the council captures all relevant information on biodiversity loss and gain."
Therefore, it is not just major developments that will be evaluated.
More information, principles and guidance for the UK construction industry and developers on the adoption of Biodiversity Net Gain for developments is provided by CIEEM.
How does it work?
When considering development sites, there will need to be an assessment of the existing biodiversity value of the site ('Biodiversity Accounting'). This uses a 'biodiversity metric' to calculate the value of each habitat and its condition, based on the professional judgement and evidence submitted by a Suitably Qualified Ecologist within a Preliminary Ecological Appraisal or equivalent report, to support a planning application. This is termed the biodiversity 'baseline' for the site, pre-development and is in 'biodiversity units' or parts thereof.
The post-development score for the development site is generated through detailed consideration of the retention of habitats and the creation or enhancement of new habitats, including soft landscaping, green infrastructure and specific habitat creation or enhancement (woodland, grassland etc.) within the 'biodiversity metric'.
The post-development value is subtracted from the pre-development 'baseline value' to determine whether Net Loss or Net Gain is likely to be achieved.
Agreement on the baseline and post-development scores should be undertaken with the Biodiversity Team prior to submitting a planning application, to avoid any unnecessary delays.
If Net Loss is the likely outcome, there are two options:
The landscaping is modified to achieve No Net Loss on the development site - this may involve increasing the area(s) of habitat created, installing biodiverse roofs if they were not initially provided etc.
Compensation is paid to make the development acceptable. See 'Biodiversity Tariff' below.
Any planning permission granted will then provide a mechanism via planning conditions to secure the protection, enhancement and provision of habitat through the development, as agreed with the Biodiversity Team. This will take the form and a Biodiversity Enhancement and Management Plan (BEMP).
Sutton's adopted management and monitoring period for the delivery of No Net Loss and Net Gain is currently 30 years from the completion date of the habitat to be created.
The Council has adopted a bespoke biodiversity offsetting metric and more information on this is provided within the Technical Guidance Note. Please contact the Biodiversity Team to request a copy of the biodiversity metric, prior to submitting a planning application.
DEFRA has created a new metric '3.0', replacing DEFRA 2.0. The DEFRA 3.0 metric is not Sutton;s adopted metric, so please do not submit these but instead ask for the Council's adopted metric. IN due course, it is likely the Council will move to DEFRA 3.0 (and / or updated versions) as part of the mandatory adoption of Biodiversity Net Gain in 2023 or later, as part of an updated Local Plan.
The Council is desirous that, in many cases, that No Net Loss and Biodiversity Net Gain are delivered within the development footprint ('red line boundary') to create a permeable landscape for wildlife. However, this may not be achievable, for a variety of reasons but must always be fully justified, through discussions with, or submission to, the Council.
In instances where No Net Loss and Biodiversity Net Gain cannot be achieved within the 'red line boundary', 'Biodiversity Offsetting' will be required, which will deliver the actions adopted through the Biodiversity Strategy, including habitat creation. 'Offsetting' will be paid for by means of a 'Biodiversity Tariff' imposed on the development.
The Biodiversity Strategy is clear on when a Biodiversity Tariff will be utilised:
"The London Borough of Sutton will utilise Biodiversity Net Gain to maximise on-site mitigation and enhancement for biodiversity, where this provides the best outcomes for nature, including the connectivity of habitats.
However, given the ambitious short and long-term targets outlined in this Biodiversity Strategy, it may be better, ecologically, to accept some Net Loss, on some specific developments, to deliver wider improvements at the landscape scale.
The determination of each development will be on a case-by-case basis to decide on what the ‘best ecological outcome’ may be, which may be to deliver on site or, to fund a habitat creation or restoration project, as outlined within this Strategy.
Any Net Loss allowance will be based on robust consideration of the development and ecological connectivity by the Biodiversity Team. It is not ‘a Licence to Trash’ a site.
The deliberate and / or intentional degrading of a site, through vegetation clearance, neglect etc. to attempt to reduce the baseline units for a forthcoming planning application and circumvent the planning process, will necessitate the estimation of the baseline value of the site, prior to any degradation. This estimation will be based on the best available data." (Appendix B5, 2.1.2 Delivery, pg.66)
The Council has adopted, through the Biodiversity Strategy, a specific 'unit cost' for biodiversity. This is further explained within Appendix B5 Green Infrastructure and Biodiversity Net Gain, section 7.1: Offsetting / Compensation Costs - ‘Biodiversity Tariff’.
A Biodiversity Tariff is the compensation cost for a development, if it does not achieve No Net Loss, as calculated through the biodiversity metric. This is consistent with the application of the 'Mitigation hierarchy', as laid out within the National Planning and Policy Framework (NPPF) "if significant harm to biodiversity resulting from a development cannot be avoided (through locating on an alternative site with less harmful impacts), adequately mitigated, or, as a last resort, compensated for, then planning permission should be refused" (para.175, a; pgs.50-51).
The tariff is calculated at different rates, based on the habitats affected. The Council's adopted metric calculates the costs of losses of woodland and scrub, semi-natural grasslands and wetlands. The Council also has a mean tariff value of £93,570.48 per biodiversity unit or part thereof for 'other habitats' i.e. those not covered under the broad habitat types above. The Biodiversity Tariff utilises a Full Cost Recovery model, rather than basing costs on 'incentives' provided through agri-environmental schemes.
As an example, if a development calculated a Net Loss to biodiversity through the metric of 0.46 units from an 'other habitat' (such as loss of garen land), then the compensation amount would be 0.46 x £93,570.48 = £43,042.42.
This compensation will be secured via a planning obligation (Section 106) prior to planning permission being granted, to deliver an 'offset' elsewhere within the borough. In all cases, the most appropriate actions within the Biodiversity Strategy will be selected to deliver the offset. The most local area / actions to the development will be considered but these may not be suitable for offsetting, for a variety of reasons.
'Green infrastructure' (GI) is a term that is used to describe those aspects of urban greening that will enhance nature's ability to deliver multiple valuable ecosystem goods and services, potentially providing a wide range of environmental, social, climate change adaptation and mitigation, and biodiversity benefits. In most cases, this will be through the provision of soft landscaping, the use of biodiverse roofs, living walls and Sustainable Drainage Systems (SuDS) that have biodiversity as a key part of their design.
The Biodiversity Strategy outlines how Sutton will apply the principles of green infrastructure to developments within Appendix B5, Section 3.2. Importantly, sedum roofs should not be used. The Council wishes to see the creation of 'biodiverse' roofs, as laid out in Policy 33 (33.12) of the Local Plan 2018-2031 and Section 3.2.1 'Living Roofs' of the Biodiversity Strategy.
Section 3.2.4 Species Requirements also includes information on how developments should not only work to protect and enhance habitats but also to provide features for locally important species, including but not limited to swifts, bats, house sparrows and hedgehogs.
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