The wellbeing of natural heritage is fundamental to our existence.LINI considers the wellbeing of natural heritage is fundamentally crucial to our environmental, human and economic wellbeing. LINI requests that an overarching aim for PPS2 must be stated as ‘nature conservation to ensure the wellbeing of our natural environment (wildlife and habitats) as a critical resource for social and economic benefit’. Understood in this manner, no ‘conflicts of interest’ are reasonable, as development for social and economic benefit relies on natural wellbeing and enhancement. Natural Heritage is a concern in all development.LINI considers that it is especially important to recognise that consideration of natural heritage is important in all planning applications, not just those within or adjacent to designated sites, and requests that this is clearly stated at the outset of a revised PPS2.Policy HierarchyThe ELC requires signatory states to recognise that ‘all landscapes matter’, so LINI reminds the Department that these provisions apply to any matters of natural heritage which might be impacted by development, whether or not this is within or adjacent to a designated site. Therefore, LINI requests that the section entitled ‘Other Species, Habitats and Features’ should be retitled ’All Species, Habitats and Features’ and should be the first section of the PPS and SPG. The other sections would detail additional considerations to be made due to their designation level. This will present a clear hierarchy of importance in policy terms.Northern Ireland Landscape Character Assessment (2000)In Northern Ireland, the ELC is partially met through the Northern Ireland Landscape Character Assessment (NILCA 1999), which comprises landscape and visual assessment of 130 distinct units of landscape, along with the statement of several quality objectives for each one. LINI is concerned that these objectives are not sufficiently regarded by planning (development control), and also that the NILCA has not been adequately updated since its creation in 1999. LINI advises that the LCA process should more clearly encompass matters of geophysical foundation (land, water, climate); living surface elements (vegetation, fauna, human); habitat (the place-qualities of life); visual presence; sensual matters (including legend); change (eg. Historic Landscape Characterisation). LINI requests that all development be required to adhere to the NILCA, and to principles of Ecosystem Services and principles of Green Infrastructure. Areas of Outstanding Natural Beauty (AONB)As AONBs are designated not solely for reasons of natural heritage but also human interaction, LINI suggests that policy relating to AONB could form part of a revised PPS6 for landscape (built, rural and seascape), alongside Conservation Areas etc. LINI is concerned that whereas policies for ‘natural heritage’ matters result in automatic presumption against development, policy relating to AONBs embodies a presumption in favour of development. AONBs are national ‘landscape’ designations. The term ‘landscape’ (as confirmed by the European Landscape Convention) is inclusive of townscape, rural countryside, and seascape. LINI requests that the Department reconsider the planning presumption of policy NH6, as the AONB definition is dependent on the wellbeing of its natural heritage to fulfill its designation. Landscape is an interaction between human and nature, and where a distinct unit of landscape character has been identified with specific quality objectives drawn up for it, LINI considers that the ELC prescribes a presumption against development causing adverse impact to that recognised character (ie. should be a presumption against equally for AONB as for species and habitats). It must be very clear in all cases that all development must enhance the natural and landscape value of its environment, or it will not be permitted.
|Number of pages||9|
|Publication status||Published (in print/issue) - Jul 2011|