NEDDC Local Plan Issues and Options Consultation on the Strategic Approach to the Location of Development and Refined Sites (March 2026)

Strategic Approach to location of Development
In accordance with paragraph 181 of NPPF, the local plan should allocate land with the least environmental or amenity value. Natural England expects sufficient evidence to be provided, through the Sustainability Appraisal and Habitats Regulations Assessment, to justify the site selection process and to ensure sites of least environmental value are selected, e.g. land allocations should avoid designated sites and landscapes and significant areas of best and most versatile (BMV) agricultural land and should consider the direct and indirect effects of development, including on land outside designated boundaries and within the setting of protected landscapes.
Allocated sites should incorporate opportunities for Green Infrastructure, and we recommend that reference is made to the Green Infrastructure Framework: Principles & Standards (Green Infrastructure Home) which provides detailed information and up to date guidance on the provision of Green Infrastructure.
Any site for allocation in the local plan should clearly set out the Biodiversity Net Gain requirements for the development including both on-site and where appropriate off-site provision.
We also highlight the need to consider the advice and recommendations within the Derbyshire Local Nature Recovery Strategy (Homepage - Derbyshire's Nature Recovery Strategy)

Sustainability Appraisal
Natural England has reviewed the Sustainability Appraisal (SA) and considers that it provides a comprehensive assessment at this stage of the Local Plan and is an addendum to the Issues and Options Report (2025) consultation.

SSSIs
We note that section C2.2.2 states that eleven sites (45049, 45078, 45085, 45217, 45483, 45900, 45909, 45049, 45097, 45098, 45169 and 45460) fall within an IRZ which indicates that consultation may be required with Natural England. These sites if taken forward would need to provide sufficient information to provide evidence that the proposal would not damage or destroy the interest features for which the SSSI has been notified. Mitigation strategies provided to reduce adverse impacts on SSSIs should offer positive opportunities for nature and should be set out in sufficient detail to ensure their long-term protection and enhancement.

Peak District National Park Landscape
We note that in section C.3.1.2 that the majority of the proposed sites are located more than 5km from the PDNP boundary and are therefore unlikely to impact on landscape of the National Park on an individual basis. The SA report notes however that cumulatively the allocations could result in an impact on the landscape of the National Park and its setting. Natural England therefore agrees with the recommendation that the relevant development proposals are supported by an appropriate Landscape and Visual Impact Assessment (LVIA).

BMV land
The SA explains, at C.7.2.3, that a total of 145 sites contain Grade 3 land. Of these sites, eight are larger than 20ha, including Sites 45909 and 45226 which wholly comprise Grade 3 land. Soil is a finite resource which plays an essential role within sustainable ecosystems, performing an array of functions supporting a range of ecosystem services, including storage of carbon, the infiltration and transport of water, nutrient cycling, and provision of food. Natural England would advise that if these sites were taken forward that any grant of planning permission should be made subject to conditions to safeguard soil resources, including the provision of an appropriately experienced soil specialist to advise on and supervise soil handling. Sustainable soil management should aim to minimise risks to the ecosystem services which soils provide, through appropriate site design and Green Infrastructure provision.

Greenspace
Section C.12.5.3 explains that 193 sites are not located within the recommended sustainable walking distance of any identified green space typology and therefore have limited opportunities for access to recreational resources. We also note that at C.12.6.3 that at 23 sites there would be a substantial net loss of publicly accessible green infrastructure and are therefore assessed as having a major negative effect.
Natural England recommends that the Green Infrastructure Framework (GIF) is considered and referred to as it provides valuable tools and resources to address the inequity of access to greenspace and nature. The GIF has been prepared to address the Environmental Improvement Plan’s commitment 86 “Make sure that everyone has access to green or blue spaces within a 15-minute walk from home.” The Local Plan policies should ensure that health and wellbeing outcomes are being maximised for all by enabling access to nature for the mental and physical health benefits by trying to achieve the “Green in 15” target.

HRA Screening report
Natural England welcomes the Habitat Regulations Assessment which has been prepared as an addendum to the previous HRA for the Issues & Options document and assesses the refined list of potential site allocations. We acknowledge that the HRA report provides a precautionary allocation-level screening at this stage of the local plan process which will be followed up at the Regulation 19 consultation. We agree with the approach and methodology that the screening exercise has followed to identify the Habitat Sites (European Sites) and the Likely Significant Impacts (LSE) that may result from the potential allocations.
We note that a high-level preliminary Appropriate Assessment has been undertaken to consider avoidance and mitigation measures and which will be used to inform the refinement of the spatial strategy and the selection of allocation sites and policy wording as the plan progresses and will be followed up with full Appropriate Assessment.
We note at section 7.4 of the HRA report that it has been highlighted that Lepus consulting and NEDDC should work closely with Natural England to develop appropriate mitigation strategies, to avoid public access and disturbance LSEs at screened in European sites. Natural England would welcome this opportunity to discuss this topic further so that effective mitigation strategies can be prepared where appropriate.