Comment

Representation ID: 11567

Received: 17/03/2021

Respondent: Yorkshire Wildlife Trust

Pleased to see commitment to at least 10% net gain for biodiversity included within supporting text. To ensure clarity would be better within the policy wording.

Would support rewording of supporting text (4.26.16 onwards) - this is misleading and misrepresents purpose of the mitigation hierarchy and biodiversity net gain (BNG). Should be made clear that the Mitigation Hierarchy is not part of BNG considerations; it is additional to the application of the mitigation hierarchy which must first be considered in line with legislation.

Clarity should be made that loss of and impacts upon designated sites and priority habitats are not appropriate for inclusion within any metric calculations and bespoke compensation will be required, should avoidance not be possible for reasons of overriding public interest.

Policy - Section K - clarity should be made that offsets will need to be secured and maintained/monitored for a minimum of 30 years (BS 8683).