We recommend that it is specified in the pre-submission Local Plan that the frameworks and masterplans for each development must include clear and evidenced strategies to avoid increasing recreational pressure on internationally designated wildlife sites, in line with duties on the Council to conserve biodiversity.

We welcome the Councils' commitment to the strategic mitigation plan currently under development for recreational impacts of new housing developments on internationally-designated sites, known as the Recreational Avoidance and Mitigation Strategy (RAMS). Where a development is likely to give rise to a significant effect on an internationally designated site and it is possible to mitigate this effect, developers should be required to contribute to the RAMS, to ensure that mitigation is strategic rather than piecemeal, and give confidence that mitigation measures can be delivered. We recommend that these requirements are specified within an appropriate policy in the Local Plan.

In order to understand whether measures to protect sensitive sites are being effective, there needs to have been a baseline of monitoring conducted to understand the extent and type of pressure these sites face. Information from this monitoring can then be used to inform the RAMS, which from experience elsewhere in the UK, we know will require paid wardens/rangers to be employed to raise awareness of the importance of coastal sites and promote positive behaviours amongst local communities and visitors alike.

The RSPB would welcome working with SCDC, IBC and other parties, e.g. Suffolk Wildlife Trust and The Greenways Project in helping to maximise the over-arching benefits to biodiversity, residents and visitors alike of such a strategy.

Alongside the RAMS, we consider that the key means to avoid increasing pressure on designated sites will be through provision of high quality green space close to people's homes and at a scale that is appropriate to the level of planned growth. This should be wildlife rich green space, again in line with the Council's biodiversity duties. Furthermore, access to such spaces will have wider societal benefits by contributing to the health and wellbeing of residents, e.g. for dog-walking, jogging or wildlife-watching.

The RSPB welcomes the intention to deliver a "Green Rim" around Ipswich as part of IBC's strategy to alleviate recreational pressure on sensitive sites and we support the stated intention to co-operate with neighbouring planning authorities on this matter.

All developments should be nature friendly, with homes for nature integrated with homes for people during the design phase. Providing access to high quality greenspace on people's doorsteps will help to alleviate recreational pressure on important wildlife sites from the new developments and promote a connection to nature for residents.

With the planned scale of development there will be many opportunities to bring nature closer to people at the local scale. An example of how to develop nature-friendly homes is the Kingsbrook Barratt Homes development at Aylesbury, Oxfordshire where RSPB has worked in partnership with Barratt Homes PLC to design housing that benefits people and nature (https://ww2.rspb.org.uk/our-work/conservation/projects/kingsbrook-housing). Further details on our experience working with Barratt Homes PLC and Aylesbury Vale District Council to set a positive example of nature-friendly and wildlife rich development, which we would like to see as the new common standard is provided in Annex 1.

Offering the opportunity for increased connection to nature within the development, through accessible and wildlife-rich green space and wildlife friendly gardens benefits both the natural environment and maximises the health and well-being benefits for residents. The benefits of nature on people's mental health are widely reported within scientific literature; however, recently it has become apparent that the quality of the natural environment may be more important than the quantity of it. People are twice as likely to report low psychological distress when living close to quality green space compared with those living near low quality green space [Francis, J., Wood, L.J., Knuiman, M., and Giles-Corti, B. (2012) Quality or Quantity? Exploring the relationship between Public Open Space attributes and mental health in Perth, Western Australia. Social Science and Medicine 74: 1570 - 1577.].

Therefore, it is important not only to plan for easy access to green spaces in our living environment but also to improve the quality of these green spaces - incorporating greater levels of biodiversity in our green spaces could be one way to achieve this.

Natural England have established methods to calculate how much green space will be required in relation to the level of recreational need, known as the Accessible Natural Greenspace Standard (http://publications.naturalengland.org.uk/category/47004). We recommend these methods provide the basis of calculating necessary greenspace for new developments.

The RSPB would be grateful for the opportunity to provide further advice on these matters during preparation of the pre-submission version of the Local Plan.

One of the main pressures identified on designated sites is dogs off-lead. New developments should therefore be managed with dog-walkers in mind and have accessible green space within easy walking distance. The average dog-walk is 2.7km and a dog-owner will only walk around 4-500m to begin exercising their dog, otherwise they are likely to drive to a site to do so. This in itself, adds unnecessary traffic to roads and will increase air pollution and heighten the risk of sensitive sites being disturbed.

Hampshire County Council have produced a guidance document called Planning for dog ownership in new developments: reducing conflict - adding value. Access and greenspace design guidance for planners and developers (March 2013) which provides greater detail.

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