Having viewed the document, the Sussex Wildlife Trust questions the soundness of the Development Management Plan. In particular whether the plan is consistent with national policy and sufficiently performs its environmental role of:

'contributing to protecting and enhancing our natural, built and historic environment; and, as part of this, helping to improve biodiversity, use natural resources prudently, minimise waste and pollution, and mitigate and adapt to climate change including moving to a low carbon economy'

In the plan making section of the National Planning Policy Framework (NPPF), paragraph 152 states that: 'Local Planning Authorities should seek opportunities to achieve each of the economic, social and environmental dimensions of sustainable development, and net gains across all three...'

The Sussex Wildlife Trust is concerned that the natural environment and natural capital needed to deliver sustainable housing in Hastings will be compromised from the allocations that are suggested in the local plan. This is because as the plan currently stands, the allocation maps indicate that there are:

* 3 allocations adjacent to SSSI
* 5 allocations in Local Wildlife Sites
* 15 allocations adjacent to Local Wildlife Sites
* 2 allocations in Ancient Woodland
* 10 allocations adjacent to Ancient Woodland
* 2 allocations adjacent to other Priority Habitats
* 6 allocations adjacent to Local Nature Reserves

The Sussex Wildlife Trust questions whether the allocations which are adjacent to and on existing sites designated for their biodiversity value sit in line with NPPF section 109:

'The planning system should contribute to and enhance the natural and local environment by: Minimising impacts on biodiversity and providing net gains in biodiversity where possible, contributing to the Government's commitment to halt the overall decline in biodiversity, including by establishing coherent ecological networks that are more resilient to current and future pressures'.

The Trust's concerns are particularly highlighted through the continued squeeze on Marline Woods SSSI. This ancient woodland site and associated sensitive ghyll stream is allocated to face further pressure from LRA6 (Queensway North) and LRA9 (Marline Fields). We are concerned that there is a conflict between these allocations and paragraph 118 of the NPPF which states:

'Proposed development on land within or outside a Site of Special Scientific Interest likely to have an adverse effect on a SSSI (either individually or in combination with other developments) should not normally be permitted. Where an adverse effect on the site's notified special interest feature is likely, an exception should only be made where the benefits of the development, at this site, clearly outweigh both the impacts that is likely to have on the features of the site that make it of special scientific interest and any broader impacts on the national network of SSSI.'

'Planning permission should be refused for developments resulting in the loss or deterioration of irreplaceable habitats, including ancient woodland and the loss of aged or veteran trees found outside ancient woodland unless the need for, and benefits of, the development in that location clearly outweighs the loss.'

The Sussex Wildlife Trust acknowledges that the policies for the allocations in or adjacent to designated sites included requirements for ecological opportunities and constraint maps. However we feel that given the significant designation of some of the sites that may be impacted, this information should be more rigorously investigated prior to allocation. This would ensure the plan and future planning applications sit inline with paragraph 110 of the NPPF:

'In preparing plans to meet development needs, the aim should be to minimise pollution and other adverse effects on the local and natural environment. Plans should allocate land with least environmental or amenity value where consistent with other policies in this Framework.'

We welcome and recognise that Hastings Borough Council has undertaken work to create a Green Infrastructure Strategy. However, it is vital that the individual sensitivities of the sites mapped in this document are not overlooked when they are being considered as suitable areas to deliver accessible natural green space for suggested development allocations.

The Trust strongly urges the inspector to look at the plan's site allocations and their impact on the delivery of natural capital. We are keen to see that the plan is looked at in its entirety to ensure it delivers an ecological coherent network and that all development recognises the benefits of ecosystem services as per section 109 of the NPPF:

'The planning system should contribute to and enhance the natural and local environment by: recognising the wider benefits of ecosystem services.'

The Trust feel that Hastings Borough Council should look at some of their site allocations again in order to ensure that the plan is consistent with national policy and passes the test for soundness.