We welcome the aspirations of this strategic objective with the caveat that the wording should be amended to include mention of biodiversity, as follows:

"...where our natural heritage and biodiversity are protected and enhanced..."

In order to comply with the requirements of the NPPF and to fully satisfy the criteria for sustainable development additional wording should be included as follows:

g. takes full account of opportunities to incorporate biodiversity in developments
"ensuring delivery of no net loss and aiming to deliver a measurable net gain in biodiversity wherever possible"

The policy does not fully satisfy the criteria for sustainable development.

We welcome the policy recognition of the value of open and green space, with the caveat that this policy statement should be amended to include contact with nature, as follows:

e. open and green space, "including contact with nature and wildlife"

It is now widely recognised that contact with nature and wildlife significantly improves health and wellbeing, for example by helping to lower levels of heart disease, obesity, stress and depression

We welcome the policy commitment to include biodiversity enhancements as an integral feature of SuDS.

We welcome the commitment to protect and enhance green and blue infrastructure, with the caveat that the wording should be amended to include mention of biodiversity, as follows:

borough's network of green and blue infrastructure (GBI) and should be protected,
planned, enhanced and managed "to maximise biodiversity"

i. deliver "measurable" environmental net gains; if there is a net loss from the development, provide provisions through offsetting. This should be quantified using a recognised biodiversity metric such as the Defra metric.

We recommend that wording should be amended to include mention of biodiversity, as follows:
b. these measures should be protected, planned, designed and managed as
integrated features of green and blue infrastructure "to maximise biodiversity"

Nature friendly development design should include integral features such as swift bricks, sparrow terraces, bat roosts, bee hotels etc. It should also have features and green corridors to help invertebrates, reptiles, hedgehogs and other mammals; wildlife-permeable boundaries between gardens and open spaces; wildflower verges and hedgerows integrated with the development.

...to deliver a healthy, walkable and climatically adapted public realm and "richly biodiverse" multi-functional green and blue infrastructure, amongst the backdrop views of the Essex countryside.

DH01b: LANDSCAPE-LED.

With regards to DH01b, we are disappointed to note that there is no mention of net gains. In order to accord with the NPPF and to deliver a genuinely sustainable development, there must be a policy commitment to deliver no net loss, and aim to deliver a measurable net gain in biodiversity.

We would advise that the policy should be amended to include this.

We wish to clarify that we do not support this development and remain concerned about the ecological and environmental impacts of this strategic allocation. However, we welcome the Development Principle to design and build with nature.

The Dunton Hills development and the houses themselves should be designed to integrate space for both wildlife and people, as well as to reduce carbon emissions and minimise water usage.

The development should protect and retain existing wildlife habitats, such as Eastlands Spring LoWS, hedgerows, etc. and connect them with wildlife-rich gardens, verges, amenity green space, cycle paths and walkways. The aim should be to create a network of natural green corridors weaving through the development, into the surrounding urban and rural landscapes and contributing to the wider ecological network.

This approach will improve air quality, reduce surface water flooding and make the development greener and more attractive as a place to live. Residents should have easy access to safe, beautiful, natural space for exercise, play and social interaction. Contact with nature and wildlife should become part of everyday life.

Ecological Networks, Biodiversity Net Gain, Green Infrastructure and Public
Realm
C.
a. a highly connected and biodiverse ecological network that incorporates existing habitats of value and natural features, "delivers a net measurable gain in biodiversity", and where relevant new habitats such as trees, tree lines and hedges, hedgerows, ponds and
lakes...

We wish to make clear that we remain concerned about the ecological and environmental impacts of this strategic allocation. With regards to the proposed spatial design we neither support nor object to this policy but retain a neutral position.

We welcome the following policy statement, but are of the opinion that the commitment to delivering biodiversity net gain needs to be clearly and unequivocably stated:
Ecological Networks, Biodiversity Net Gain, Green Infrastructure and Public
Realm
C.
a. a highly connected and biodiverse ecological network that incorporates existing habitats of value and natural features, and where relevant new habitats such as trees, tree lines and hedges, hedgerows, ponds and
lakes...
We would advise that the policy wording should be amended.

With regards to statement (b):

b. a variety of activity nodes and treatments for recreation and leisure opportunities throughout the GBI, including public natural parkland,
pockets of village greens, local nature reserve, allotment sites, sports pitches and fields;

We wish to add the following comment:
The south-facing slopes of the central ridge provide an ideal location for the recreation of Thames Terrace-type grassland habitat

Eastlands Spring LoWS should be protected, buffered and enhanced; designation as a local nature reserve and appropriate management to maximise biodiversity should provide a wildlife-rich, natural environment in perpetuity.


The development should provide:

* Real, measurable gains for wildlife and biodiversity and make a demonstrable, positive contribution to nature's recovery.

* Effective water management, pollution and climate control provided by green spaces, sustainable urban drainage, green roofs where possible, trees, hedgerows, wildflower meadows and other natural features.

* Connectivity between wild spaces - enabling both wildlife and people to move through the landscape, and for natural processes to operate effectively.

* Improved health, wellbeing and quality of life for people living and working nearby.

* Easy access to high quality, wildlife-rich, natural green space for everyone, providing daily opportunities to experience wildlife.

Benefits of this approach

A housing development designed with environmental sensitivity and green infrastructure at its heart can deliver multiple social, environmental and economic benefits. Nature-rich housing can provide benefits for everyone - from developers to home-owners.

Benefits for wildlife:

* No loss of key wildlife sites - better protection of the already diminished wildlife resource.

* More space for wildlife - a substantial increase in the creation and restoration of habitats, through additional funding and resources, for example Section 106 agreements and conservation covenants - contributing to an overall increase in the abundance and diversity of wildlife and an improvement of soil and catchment health.

* Improved connectivity of wildlife habitats - both within the development and linking to the wider landscape and ecological networks beyond.

* Buildings that are more wildlife-friendly - with integral swift, sparrow and bat boxes, pollinator and insect-friendly structures and connected spaces for hedgehogs.

* Reduced emissions - reducing carbon emissions, pollutants and water use to help minimise threats to wildlife.

Benefits for people:

* Daily enjoyment of nature - residents will experience and benefit from contact with wildlife and wild places in their daily lives, because there is wildlife around them near to home.

* Improved health - accessible natural green spaces for fresh air, exercise and quiet contemplation improve health and wellbeing, for example by helping to lower levels of heart disease, obesity, stress and depression.

* Protection against extremes of climate - natural green spaces and trees within the development will help stabilise temperature and reduce pollution.

* Safer transport routes - networks of natural green spaces will provide safe and attractive pedestrian and cycle routes.

* Sense of community - natural green space in and around housing can provide a shared space for the local community to come together and socialise - reducing isolation.

Benefits for the economy and wider society:

* Cost-effective environmental protection - providing green space in and around housing is a cost-effective and sustainable way of increasing environmental resilience, for example by reducing surface water flooding and improving air quality.

* Employment - if the new residential community can get involved in the planning and management of the natural green space within the development this could provide jobs and volunteering opportunities.

* Space for local food - networks of natural green space in and around housing areas provide opportunities for local food production

* Attracting investment - a high quality development rich in natural green space will attract further investment from business and visitors.

* Reduced health-care costs - people living in developments with more green space are likely to place fewer demands on the NHS, as they enjoy better health and higher quality of life.


Benefits for developers:

* Satisfied customers - houses and developments set in natural green space are more desirable to buyers.

* Market value - houses in greener developments can have a higher market value.

* Enhanced brand value - developers that take a lead on nature build their brand and change the sector as a whole.

* Improved high-calibre skills recruitment - such developers are also more likely to attract up-and-coming graduates by demonstrating a genuine commitment to the environment.

* Improved environmental performance - helping drive higher ranking in sustainability and nature indices, making the direct links to the benefits of a natural capital approach.

* Happier communities - new houses designed to retain existing natural features with high quality greenspace are more acceptable to existing residents.

Principles guiding this approach

The Dunton Hills development should result in:

* A measurable improvement for wild species and habitats, avoiding any loss of or damage to Eastlands Spring LoWS and other wildlife habitats.

* More than compensating for any habitat that is lost - where damage to existing habitats is unavoidable, mitigation must bring about an overall gain in habitats. This should be assessed objectively using an improved version of the Defra biodiversity metric.

* Creating new habitat - habitat creation should be a standard feature of all new housing development, wherever it is.

* Designing in existing habitats - the new housing must work with as much existing habitat as possible. For example, retaining the existing local wildlife site and stream, the copses and hedges as integral features of the new development.

All residents having lasting access to nearby nature, which means:

* Providing wildlife on the doorstep - space for wildlife must be designed into the new development, much of this should be easily accessible to people.

* Ensuring the natural spaces are well managed for posterity - maintaining local green spaces is as essential as maintaining roads, power and other important infrastructure. Financial planning should account for this at the outset, through a service charge or capital endowment.

* Empowering communities - Dunton Hills is a major housing development and provision should be made to empower local residents to come together to maintain shared spaces, grow food and understand the area they live in.

* Engaging civil society - local charities and social enterprises have skills and experience that will be vital to ongoing community engagement.

This can be ensured by:

* Using ecological network maps - such maps should be developed from local, up to date data

* Developing within environmental limits - decisions about the planning, design and construction of new housing must be based on a thorough understanding of the natural environment's capacity to meet the demands placed on it.

* Employing ecological expertise - when making decisions on land use and new development planning authorities should consult experienced ecologists and ensure they have access to high quality wildlife and environmental data.

f. provision for new multi-functional green infrastructure, including public open space, "to deliver a measurable net gain in biodiversity"

The policy should include a clear statement on delivering a measurable net gain in biodiversity.