From: Coath, Dominic (NE)

Sent: 24 July 2009 10:57

To: Eve Campbell

Cc: Losse, Paul (NE)

Subject: Draft Scoping Opinion for the Greenwich Park Equestrain Event

Dear Eve,

Many thanks for providing Natural England with an opportunity to provide comments on the draft scoping opinion for the Greenwich Park Equestrian Event. Overall we are happy with the scope of the EIA in respect of the potential impacts on the natural environment that will be assessed. The completed and proposed ecological surveys should be sufficiently comprehensive to provide a detailed baseline against which to assess these impacts.

We support Ecology Consultancy's recommendations but in addition to implementing measures to avoid direct physical damage and nutrient inputs, impacts of course preparation and re-instatement should be considered and minimised. These include changes to the mowing regime, watering, soil aeration and post-event reseeding (if proposed). A temporary relaxation of the mowing regime is unlikely to be detrimental, but the other treatments could be.

The report should also consider compensatory measures including changes to the grassland management regime post games. LOCOG should use this as an opportunity to provide a lasting legacy for the natural environment by increasing the quantity and quality of acid grassland and exploring any other opportunities for biodiversity gain. The opportunities to provide enhancements through habitat management and creation have not been fully drawn out in the draft Scoping Opinion. The key principles in PPS9 go beyond the aim that all planning decisions should prevent harm to biodiversity (as stated in Section 8.2.3 of the main report), placing an expectation to conserve and enhance biodiversity.  Paragraph 14 of PPS9 states that “Development proposals provide many opportunities for building-in beneficial biodiversity or geological features as part of good design. When considering proposals, local planning authorities should maximise such opportunities in and around developments, using planning obligations where appropriate.”  In addition we would draw your attention to London Plan Policy 3D.14, which states that “The planning of new development and regeneration should have regard to nature conservation and biodiversity, and opportunities should be taken to achieve positive gains for conservation through the form and design of development. Where appropriate, measures may include creating, enhancing and managing wildlife habitat and natural landscape and improving access to nature.” Finally, the London 2012 Sustainability Plan has a stated aim to `... enhance the ecology of the Lower Lea Valley and other London and regional 2012 venues, and to encourage the sport sector generally to contribute to nature conservation and enhancing the natural environment.' We would refer you to their latest report which can be found at http://www.cslondon.org/documents/CSL_2008_Annual_Review.pdf

I hope that this makes Natural England's position at this stage clear but if you have any further questions then please do not hesitate to contact me.

Yours sincerely

Dominic Coath MIEEM

Senior Specialist (Planning)

Natural England 
6^th Floor 
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Tel: 0207 060 2205

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Natural England is working to enhance biodiversity, landscapes and wildlife in rural, urban, coastal and marine areas; promote access, recreation and public well-being, and contribute to the way natural resources are managed so that they can be enjoyed now and by future generations.