Comment

Representation ID: 29191

Received: 24/03/2021

Respondent: Environment Agency

We recommend the inclusion of the following additional bullet point / paragraph within the Biodiversity & Development section of the policy wording:

“As well as assessing area-based (terrestrial) habitats, the DEFRA Biodiversity Metric includes two distinct supplementary modules for linear habitats (A: Hedgerows and lines of tress & B: Rivers and streams). Development proposals must be supported by evidence to demonstrate the achievement of measurable biodiversity net gains in each of the individual habitat types present within the proposed site regardless of likely adverse impacts. The biodiversity units calculated through the core habitat area-based metric and each of the supplementary linear-based modules are unique and cannot be summed or converted. When reporting biodiversity gains or losses with the metric, the different biodiversity unit types must be reported separately and not summed to give an overall biodiversity unit value”.

This reasoning is to ensure that the policy wording is in line with the latest Biodiversity Metric guidance. It is also to ensure that linear habitat types (e.g. hedgerows & river and streams) are included, not omitted, from BNG assessments.