Object

Representation ID: 18399

Received: 24/03/2021

Respondent: Johnson Mowat

Johnson Mowat supports and endorses the position of the Home Builders Federation as set out in its representations regarding draft Policy EN2.

Part H of the draft Policy indicates that all development should deliver a measurable net gain in biodiversity value. Whilst paragraph 4.26.11 states that ‘to demonstrate biodiversity net gain, the development must raise the score by at least 10%’ this measure should be stated in the policy wording for clarity and consistency with Government policy.

As the HBF representations state, 10% gain provides certainty in achieving environmental outcomes, deliverability of development and costs for developers. As the specific requirement offers developers a level playing field nationally and reduced risks of unexpected costs and delays, the Council should not deviate from the Government’s proposals.

As there are significant additional costs associated with biodiversity gain, this should be fully accounted for in the Council’s updated viability assessment.