We have been engaged in Eastleigh Borough Council’s emerging Local Plan since responding to the ‘Issues and Options’ consultation in February 2016. We are still gravely concerned that declines in wildlife are still happening locally and nationally and the 2016 State of Nature report highlights the urgency of addressing this issue, while the 2010 Making Space for Nature report by Sir John Lawton calls for ‘more, bigger, better and joined’ sites for biodiversity.

To this end we would wish to see a Local Plan for Eastleigh which recognises its wealth of wildlife as an asset and plans not only for its protection but for its enhancement. We would expect to see the Borough identify and utilise an objectively defined ecological network map, and policy and strategy for securing ‘net gains’ for biodiversity in line with the National Planning Policy Framework. The Borough Council has shown previous commitment in this area but we are disappointed that this now seems to be lacking.

Since 2016 we, along with other consultees, have been invited to, and attended, meetings hosted by Eastleigh Borough Council to discuss the emerging proposals and potential impacts on the suite of fragile and sensitive species and habitats present within the Borough.

In addition, the Trust’s consultancy has independently been carrying out surveys along the River Itchen in order to establish the current status of Southern Damselfly (Coenagrion mercuriale) and the suitability of some sites for habitat restoration in order to improve the resilience of the species (which is currently undergoing a dramatic decline) and address any identified potential adverse impacts – this objective assessment reflects over a decade’s worth of expertise on this species.

We acknowledge that the Council has been put in a difficult position following the Government’s Planning Inspector’s decision that the previous plan did not provide sufficient housing provision. We also acknowledge that to deliver this level of housing, new sites have to come forward for development.

However, we have serious concerns that the overall scale of development proposed in the Borough is unsustainable and because of this most of the options being proposed will have significant adverse impacts on the natural environment. We are especially concerned about fragile and irreplaceable habitats, such as the River Itchen Special Area of Conservation (SAC) and areas of ancient/semi-natural woodland and the species they support.

We do not consider it our place to direct the Borough Council to areas that could be developed but rather highlight areas that we consider to be of the highest ecological value. Highly sensitive and fragile areas where development, and the associated infrastructure, could cause the greatest adverse impact must be avoided.

For example, the River Itchen SAC and its surrounds is noted as one of the world’s premier chalk streams and is highlighted as being of national and international importance. Any proposals that would adversely impact the river, its floodplain and the species it supports, or prevent future enhancement must be avoided.

Currently, some of the options being proposed in this emerging plan would see housing and the supporting infrastructure encroaching into sensitive areas that not only support an abundance of wildlife but also floodplain areas which could offer a crucial ecosystem service in the future as we adapt to climate change. Areas of ancient/semi-natural woodland are amongst the most biodiverse habitats that have developed over hundreds of years. These are acknowledged as being highly valued and irreplaceable habitats and should be protected, from the direct and indirect impacts of residential development.

The Borough of Eastleigh has a rich and diverse natural environment but it is a finite resource which cannot be replaced once it has been lost.

As we have previously stated we have serious concerns with elements of most of the options being proposed in this draft plan since they appear to directly impact the River Itchen SAC and its interest features or other sensitive sites. We consider that this plan should aim to maintain and enhance functioning ecological networks and should be informed by detailed ecological network mapping to ensure that the most biodiverse areas are protected and enhanced, and that truly sustainable development is delivered.