Consultation Question 40

Object

Representation ID: 23444

Received: 23/03/2021

Respondent: Martin Tyson

We fully support a policy which protects, enhances, restores and expands biodiversity and geodiversity. We have a concern over existing flora and fauna being under threat from new development - especially on Green Belt. Compensation for loss of existing biodiversity and offsetting should [4.26.17] be a last resort. How do we qualify and quantify where we need to exercise this last resort? Compensation seems to be an easy approach for developers who might make large profits from Green Belt sites. How do we protect these sites now and in the future? Do we have examples of proposals for how compensation works well and produces good results for communities? How do we get properly independent assessments on impact of development? How do we decide and who decides that benefits of a development outweighs the importance of the biodiversity interest (G)? How will the council promote recommendations for household applications [4.26.12]?

Object

Representation ID: 23619

Received: 22/03/2021

Respondent: Sandra Auty

We fully support a policy which protects, enhances, restores and expands biodiversity and geodiversity. We have a concern over existing flora and fauna being under threat from new development - especially on Green Belt. Compensation for loss of existing biodiversity and offsetting should [4.26.17] be a last resort. How do we qualify and quantify where we need to exercise this last resort? Compensation seems to be an easy approach for developers who might make large profits from Green Belt sites. How do we protect these sites now and in the future? Do we have examples of proposals for how compensation works well and produces good results for communities? How do we get properly independent assessments on impact of development? How do we decide and who decides that benefits of a development outweighs the importance of the biodiversity interest (G)? How will the council promote recommendations for household applications [4.26.12]?

Object

Representation ID: 24131

Received: 23/03/2021

Respondent: Mr David and Elise Howe

We fully support a policy which protects, enhances, restores and expands biodiversity and geodiversity. We have a concern over existing flora and fauna being under threat from new development - especially on Green Belt. Compensation for loss of existing biodiversity and offsetting should [4.26.17] be a last resort. How do we qualify and quantify where we need to exercise this last resort? Compensation seems to be an easy approach for developers who might make large profits from Green Belt sites. How do we protect these sites now and in the future? Do we have examples of proposals for how compensation works well and produces good results for communities? How do we get properly independent assessments on impact of development? How do we decide and who decides that benefits of a development outweighs the importance of the biodiversity interest (G)? How will the council promote recommendations for household applications [4.26.12]?

Object

Representation ID: 24175

Received: 23/03/2021

Respondent: Helen Stocker

We fully support a policy which protects, enhances, restores and expands biodiversity and geodiversity. We have a concern over existing flora and fauna being under threat from new development - especially on Green Belt. Compensation for loss of existing biodiversity and offsetting should [4.26.17] be a last resort. How do we qualify and quantify where we need to exercise this last resort? Compensation seems to be an easy approach for developers who might make large profits from Green Belt sites. How do we protect these sites now and in the future? Do we have examples of proposals for how compensation works well and produces good results for communities? How do we get properly independent assessments on impact of development? How do we decide and who decides that benefits of a development outweighs the importance of the biodiversity interest (G)? How will the council promote recommendations for household applications [4.26.12]?

Object

Representation ID: 24214

Received: 24/03/2021

Respondent: Ellie Keighley

We fully support a policy which protects, enhances, restores and expands biodiversity and geodiversity. We have a concern over existing flora and fauna being under threat from new development - especially on Green Belt. Compensation for loss of existing biodiversity and offsetting should [4.26.17] be a last resort. How do we qualify and quantify where we need to exercise this last resort? Compensation seems to be an easy approach for developers who might make large profits from Green Belt sites. How do we protect these sites now and in the future? Do we have examples of proposals for how compensation works well and produces good results for communities? How do we get properly independent assessments on impact of development? How do we decide and who decides that benefits of a development outweighs the importance of the biodiversity interest (G)? How will the council promote recommendations for household applications [4.26.12]?

Object

Representation ID: 24327

Received: 24/03/2021

Respondent: Mr Benjamin Statham

We fully support a policy which protects, enhances, restores and expands biodiversity and geodiversity. We have a concern over existing flora and fauna being under threat from new development - especially on Green Belt. Compensation for loss of existing biodiversity and offsetting should [4.26.17] be a last resort. How do we qualify and quantify where we need to exercise this last resort? Compensation seems to be an easy approach for developers who might make large profits from Green Belt sites. How do we protect these sites now and in the future? Do we have examples of proposals for how compensation works well and produces good results for communities? How do we get properly independent assessments on impact of development? How do we decide and who decides that benefits of a development outweighs the importance of the biodiversity interest (G)? How will the council promote recommendations for household applications [4.26.12]?

Object

Representation ID: 24356

Received: 24/03/2021

Respondent: Katrina Kennedy

We fully support a policy which protects, enhances, restores and expands biodiversity and geodiversity. We have a concern over existing flora and fauna being under threat from new development - especially on Green Belt. Compensation for loss of existing biodiversity and offsetting should [4.26.17] be a last resort. How do we qualify and quantify where we need to exercise this last resort? Compensation seems to be an easy approach for developers who might make large profits from Green Belt sites. How do we protect these sites now and in the future? Do we have examples of proposals for how compensation works well and produces good results for communities? How do we get properly independent assessments on impact of development? How do we decide and who decides that benefits of a development outweighs the importance of the biodiversity interest (G)? How will the council promote recommendations for household applications [4.26.12]?

Object

Representation ID: 24385

Received: 24/03/2021

Respondent: Stephen Corbett

We fully support a policy which protects, enhances, restores and expands biodiversity and geodiversity. We have a concern over existing flora and fauna being under threat from new development - especially on Green Belt. Compensation for loss of existing biodiversity and offsetting should [4.26.17] be a last resort. How do we qualify and quantify where we need to exercise this last resort? Compensation seems to be an easy approach for developers who might make large profits from Green Belt sites. How do we protect these sites now and in the future? Do we have examples of proposals for how compensation works well and produces good results for communities? How do we get properly independent assessments on impact of development? How do we decide and who decides that benefits of a development outweighs the importance of the biodiversity interest (G)? How will the council promote recommendations for household applications [4.26.12]?

Object

Representation ID: 24414

Received: 24/03/2021

Respondent: James Stocker

We fully support a policy which protects, enhances, restores and expands biodiversity and geodiversity. We have a concern over existing flora and fauna being under threat from new development - especially on Green Belt. Compensation for loss of existing biodiversity and offsetting should [4.26.17] be a last resort. How do we qualify and quantify where we need to exercise this last resort? Compensation seems to be an easy approach for developers who might make large profits from Green Belt sites. How do we protect these sites now and in the future? Do we have examples of proposals for how compensation works well and produces good results for communities? How do we get properly independent assessments on impact of development? How do we decide and who decides that benefits of a development outweighs the importance of the biodiversity interest (G)? How will the council promote recommendations for household applications [4.26.12]?

Object

Representation ID: 24445

Received: 24/03/2021

Respondent: Mrs Janine Ward

We fully support a policy which protects, enhances, restores and expands biodiversity and geodiversity. We have a concern over existing flora and fauna being under threat from new development - especially on Green Belt. Compensation for loss of existing biodiversity and offsetting should [4.26.17] be a last resort. How do we qualify and quantify where we need to exercise this last resort? Compensation seems to be an easy approach for developers who might make large profits from Green Belt sites. How do we protect these sites now and in the future? Do we have examples of proposals for how compensation works well and produces good results for communities? How do we get properly independent assessments on impact of development? How do we decide and who decides that benefits of a development outweighs the importance of the biodiversity interest (G)? How will the council promote recommendations for household applications [4.26.12]?

Object

Representation ID: 24474

Received: 24/03/2021

Respondent: Catherine Hinchliffe

We fully support a policy which protects, enhances, restores and expands biodiversity and geodiversity. We have a concern over existing flora and fauna being under threat from new development - especially on Green Belt. Compensation for loss of existing biodiversity and offsetting should [4.26.17] be a last resort. How do we qualify and quantify where we need to exercise this last resort? Compensation seems to be an easy approach for developers who might make large profits from Green Belt sites. How do we protect these sites now and in the future? Do we have examples of proposals for how compensation works well and produces good results for communities? How do we get properly independent assessments on impact of development? How do we decide and who decides that benefits of a development outweighs the importance of the biodiversity interest (G)? How will the council promote recommendations for household applications [4.26.12]?

Object

Representation ID: 24559

Received: 24/03/2021

Respondent: Lyndsey Lloyd

We fully support a policy which protects, enhances, restores and expands biodiversity and geodiversity. We have a concern over existing flora and fauna being under threat from new development - especially on Green Belt. Compensation for loss of existing biodiversity and offsetting should [4.26.17] be a last resort. How do we qualify and quantify where we need to exercise this last resort? Compensation seems to be an easy approach for developers who might make large profits from Green Belt sites. How do we protect these sites now and in the future? Do we have examples of proposals for how compensation works well and produces good results for communities? How do we get properly independent assessments on impact of development? How do we decide and who decides that benefits of a development outweighs the importance of the biodiversity interest (G)? How will the council promote recommendations for household applications [4.26.12]?

Object

Representation ID: 24588

Received: 24/03/2021

Respondent: Steven Langford

We fully support a policy which protects, enhances, restores and expands biodiversity and geodiversity. We have a concern over existing flora and fauna being under threat from new development - especially on Green Belt. Compensation for loss of existing biodiversity and offsetting should [4.26.17] be a last resort. How do we qualify and quantify where we need to exercise this last resort? Compensation seems to be an easy approach for developers who might make large profits from Green Belt sites. How do we protect these sites now and in the future? Do we have examples of proposals for how compensation works well and produces good results for communities? How do we get properly independent assessments on impact of development? How do we decide and who decides that benefits of a development outweighs the importance of the biodiversity interest (G)? How will the council promote recommendations for household applications [4.26.12]?

Object

Representation ID: 24637

Received: 24/03/2021

Respondent: Michelle Schofield

We fully support a policy which protects, enhances, restores and expands biodiversity and geodiversity. We have a concern over existing flora and fauna being under threat from new development - especially on Green Belt. Compensation for loss of existing biodiversity and offsetting should [4.26.17] be a last resort. How do we qualify and quantify where we need to exercise this last resort? Compensation seems to be an easy approach for developers who might make large profits from Green Belt sites. How do we protect these sites now and in the future? Do we have examples of proposals for how compensation works well and produces good results for communities? How do we get properly independent assessments on impact of development? How do we decide and who decides that benefits of a development outweighs the importance of the biodiversity interest (G)? How will the council promote recommendations for household applications [4.26.12]?

Object

Representation ID: 24712

Received: 24/03/2021

Respondent: Danny Schofield

We fully support a policy which protects, enhances, restores and expands biodiversity and geodiversity. We have a concern over existing flora and fauna being under threat from new development - especially on Green Belt. Compensation for loss of existing biodiversity and offsetting should [4.26.17] be a last resort. How do we qualify and quantify where we need to exercise this last resort? Compensation seems to be an easy approach for developers who might make large profits from Green Belt sites. How do we protect these sites now and in the future? Do we have examples of proposals for how compensation works well and produces good results for communities? How do we get properly independent assessments on impact of development? How do we decide and who decides that benefits of a development outweighs the importance of the biodiversity interest (G)? How will the council promote recommendations for household applications [4.26.12]?

Object

Representation ID: 24750

Received: 24/03/2021

Respondent: Hamish Logan

We fully support a policy which protects, enhances, restores and expands biodiversity and geodiversity. We have a concern over existing flora and fauna being under threat from new development - especially on Green Belt. Compensation for loss of existing biodiversity and offsetting should [4.26.17] be a last resort. How do we qualify and quantify where we need to exercise this last resort? Compensation seems to be an easy approach for developers who might make large profits from Green Belt sites. How do we protect these sites now and in the future? Do we have examples of proposals for how compensation works well and produces good results for communities? How do we get properly independent assessments on impact of development? How do we decide and who decides that benefits of a development outweighs the importance of the biodiversity interest (G)? How will the council promote recommendations for household applications [4.26.12]?

Object

Representation ID: 24779

Received: 24/03/2021

Respondent: Ashera Grande

We fully support a policy which protects, enhances, restores and expands biodiversity and geodiversity. We have a concern over existing flora and fauna being under threat from new development - especially on Green Belt. Compensation for loss of existing biodiversity and offsetting should [4.26.17] be a last resort. How do we qualify and quantify where we need to exercise this last resort? Compensation seems to be an easy approach for developers who might make large profits from Green Belt sites. How do we protect these sites now and in the future? Do we have examples of proposals for how compensation works well and produces good results for communities? How do we get properly independent assessments on impact of development? How do we decide and who decides that benefits of a development outweighs the importance of the biodiversity interest (G)? How will the council promote recommendations for household applications [4.26.12]?

Object

Representation ID: 24857

Received: 24/03/2021

Respondent: Chris Knowles

We fully support a policy which protects, enhances, restores and expands biodiversity and geodiversity. We have a concern over existing flora and fauna being under threat from new development - especially on Green Belt. Compensation for loss of existing biodiversity and offsetting should [4.26.17] be a last resort. How do we qualify and quantify where we need to exercise this last resort? Compensation seems to be an easy approach for developers who might make large profits from Green Belt sites. How do we protect these sites now and in the future? Do we have examples of proposals for how compensation works well and produces good results for communities? How do we get properly independent assessments on impact of development? How do we decide and who decides that benefits of a development outweighs the importance of the biodiversity interest (G)? How will the council promote recommendations for household applications [4.26.12]?

Comment

Representation ID: 24896

Received: 24/03/2021

Respondent: CEG Land Promotions Ltd

Agent: Lichfields

Recommendations to clarify this policy:
1 In order to provide certainty the Wildlife Habitat Network mentioned in the table within Section A should be defined on the policies map.
2 Section B incorrectly refers to ‘functionally linked land’ as if it were part of the SPA in that it applies the likely significant effect test to functionally linked land. The correct test is whether the effects on functionally linked land will have a likely significant effect upon the SPA, not the functionally linked land. In order to be compliant with Habitat Regulations the text within the bracket – (or land functionally linked to the SPA) – must be deleted. The final paragraph of Section B further perpetuates this error and should be deleted in order to comply with the Habitats Regulations, 2017 (as amended). Section B is linked to Policy SP11. The proposed changes suggested for SP11 will modify the application of Section B of the policy.
3 Section C: There is no legal requirement for impacts upon SSSI to be assessed ‘in combination with other developments’ and this reference should be removed as it does not reflect the Wildlife and Countryside Act 1981 (as amended). Similarly there is no legal requirement to assess ‘broader impacts on the national network of SSSIs.’ The use of the phrase ‘at this site’ is ambiguous and should be removed.
4 Section D: The Wildlife Habitat Network needs to be defined in order to provide certainty for decision making. The policy does not allow sufficiently flexibility for mitigation and compensatory measures and should be reworded to reflect this.
5 Section I should not reference the Environment Bill, because there is no certainty as to the Bill’s final form or content.
6 Section J: There is no legal requirement to provide Biodiversity Net Gain (BNG) within a development site as a matter of priority, nor is there any legal requirement for the need to justify why gain cannot be delivered on site. The policy should be reworded to allow for
offsite mitigation in all cases. There is also no legal requirement to provide BNG compensation ‘a preference for those in the immediate vicinity’ and this should also be removed.
7 Section K substantially repeats the previous sections and should be removed.
8 Section M is unclear and ambiguously worded. BNG is a tool for securing gain in biodiversity not ‘well-being’. It is also not clear how this policy will be implemented in
practice.
9 Section N: Ecological surveys should be carried out in manner that is also proportionate to the ecological features present on the site, not just the type and scale of the development.

Object

Representation ID: 24944

Received: 22/03/2021

Respondent: Bridget Day

We fully support a policy which protects, enhances, restores and expands biodiversity and geodiversity. We have a concern over existing flora and fauna being under threat from new development - especially on Green Belt. Compensation for loss of existing biodiversity and offsetting should [4.26.17] be a last resort. How do we qualify and quantify where we need to exercise this last resort? Compensation seems to be an easy approach for developers who might make large profits from Green Belt sites. How do we protect these sites now and in the future? Do we have examples of proposals for how compensation works well and produces good results for communities? How do we get properly independent assessments on impact of development? How do we decide and who decides that benefits of a development outweighs the importance of the biodiversity interest (G)? How will the council promote recommendations for household applications [4.26.12]?

Object

Representation ID: 24973

Received: 22/03/2021

Respondent: Mr Rob Pawson

We fully support a policy which protects, enhances, restores and expands biodiversity and geodiversity. We have a concern over existing flora and fauna being under threat from new development - especially on Green Belt. Compensation for loss of existing biodiversity and offsetting should [4.26.17] be a last resort. How do we qualify and quantify where we need to exercise this last resort? Compensation seems to be an easy approach for developers who might make large profits from Green Belt sites. How do we protect these sites now and in the future? Do we have examples of proposals for how compensation works well and produces good results for communities? How do we get properly independent assessments on impact of development? How do we decide and who decides that benefits of a development outweighs the importance of the biodiversity interest (G)? How will the council promote recommendations for household applications [4.26.12]?

Object

Representation ID: 25002

Received: 22/03/2021

Respondent: Anil Mander

We fully support a policy which protects, enhances, restores and expands biodiversity and geodiversity. We have a concern over existing flora and fauna being under threat from new development - especially on Green Belt. Compensation for loss of existing biodiversity and offsetting should [4.26.17] be a last resort. How do we qualify and quantify where we need to exercise this last resort? Compensation seems to be an easy approach for developers who might make large profits from Green Belt sites. How do we protect these sites now and in the future? Do we have examples of proposals for how compensation works well and produces good results for communities? How do we get properly independent assessments on impact of development? How do we decide and who decides that benefits of a development outweighs the importance of the biodiversity interest (G)? How will the council promote recommendations for household applications [4.26.12]?

Object

Representation ID: 25032

Received: 22/03/2021

Respondent: Louise Judd

We fully support a policy which protects, enhances, restores and expands biodiversity and geodiversity. We have a concern over existing flora and fauna being under threat from new development - especially on Green Belt. Compensation for loss of existing biodiversity and offsetting should [4.26.17] be a last resort. How do we qualify and quantify where we need to exercise this last resort? Compensation seems to be an easy approach for developers who might make large profits from Green Belt sites. How do we protect these sites now and in the future? Do we have examples of proposals for how compensation works well and produces good results for communities? How do we get properly independent assessments on impact of development? How do we decide and who decides that benefits of a development outweighs the importance of the biodiversity interest (G)? How will the council promote recommendations for household applications [4.26.12]?

Object

Representation ID: 25062

Received: 22/03/2021

Respondent: Richard Watson

We fully support a policy which protects, enhances, restores and expands biodiversity and geodiversity. We have a concern over existing flora and fauna being under threat from new development - especially on Green Belt. Compensation for loss of existing biodiversity and offsetting should [4.26.17] be a last resort. How do we qualify and quantify where we need to exercise this last resort? Compensation seems to be an easy approach for developers who might make large profits from Green Belt sites. How do we protect these sites now and in the future? Do we have examples of proposals for how compensation works well and produces good results for communities? How do we get properly independent assessments on impact of development? How do we decide and who decides that benefits of a development outweighs the importance of the biodiversity interest (G)? How will the council promote recommendations for household applications [4.26.12]?

Object

Representation ID: 25096

Received: 22/03/2021

Respondent: Tina Collins

We fully support a policy which protects, enhances, restores and expands biodiversity and geodiversity. We have a concern over existing flora and fauna being under threat from new development - especially on Green Belt. Compensation for loss of existing biodiversity and offsetting should [4.26.17] be a last resort. How do we qualify and quantify where we need to exercise this last resort? Compensation seems to be an easy approach for developers who might make large profits from Green Belt sites. How do we protect these sites now and in the future? Do we have examples of proposals for how compensation works well and produces good results for communities? How do we get properly independent assessments on impact of development? How do we decide and who decides that benefits of a development outweighs the importance of the biodiversity interest (G)? How will the council promote recommendations for household applications [4.26.12]?

Object

Representation ID: 25147

Received: 23/03/2021

Respondent: Donna Radcliffe

We fully support a policy which protects, enhances, restores and expands biodiversity and geodiversity. We have a concern over existing flora and fauna being under threat from new development - especially on Green Belt. Compensation for loss of existing biodiversity and offsetting should [4.26.17] be a last resort. How do we qualify and quantify where we need to exercise this last resort? Compensation seems to be an easy approach for developers who might make large profits from Green Belt sites. How do we protect these sites now and in the future? Do we have examples of proposals for how compensation works well and produces good results for communities? How do we get properly independent assessments on impact of development? How do we decide and who decides that benefits of a development outweighs the importance of the biodiversity interest (G)? How will the council promote recommendations for household applications [4.26.12]?

Comment

Representation ID: 25172

Received: 23/03/2021

Respondent: Home Builders Federation

All development (except householder applications) should deliver a measurable net gain in biodiversity value compared with the pre-development baseline. Proposals should be supported by evidence to demonstrate a biodiversity net gain using the current Defra Biodiversity Metric.

The Council will know that the Government is already looking at the most appropriate approach to biodiversity net gain. The HBF considers that the Council should not deviate from the Government’s proposals on biodiversity gain as set out in the Environment Bill. This legislation will require development to achieve a 10% net gain for biodiversity. It is the Government’s opinion that 10% strikes the right balance between the ambition for development and reversing environmental decline. 10% gain provides certainty in achieving environmental outcomes, deliverability of development and costs for developers. 10% will be a mandatory national requirement, but it is not a cap on the aspirations of developers who want to voluntarily go further. The mandatory requirement offers developers a level playing field nationally and reduced risks of unexpected costs and delays.

The Council’s policy approach should also reflect the Government’s proposals for a transition period of two years as set out in the Environment Bill. The Government proposes to work with stakeholders on the specifics of this transition period, including accounting for sites with outline planning permission, in order to provide clear and timely guidance on understanding what will be required and when.

The Government will issue guidance to Councils on the importance of proportionality in their application of planning policy. So that sites without reasonable opportunities to achieve net gain through on-site habitat delivery will not face risks of delay through rigid or prescriptive requirements.

There are significant additional costs associated with biodiversity gain, which should be fully accounted for in the Council’s updated viability assessment. The Government has confirmed that more work needs to be undertaken to address viability concerns raised by the housebuilding industry in order that net gain does not prevent, delay or reduce housing delivery.

Object

Representation ID: 25201

Received: 23/03/2021

Respondent: Stephen Radcliffe

We fully support a policy which protects, enhances, restores and expands biodiversity and geodiversity. We have a concern over existing flora and fauna being under threat from new development - especially on Green Belt. Compensation for loss of existing biodiversity and offsetting should [4.26.17] be a last resort. How do we qualify and quantify where we need to exercise this last resort? Compensation seems to be an easy approach for developers who might make large profits from Green Belt sites. How do we protect these sites now and in the future? Do we have examples of proposals for how compensation works well and produces good results for communities? How do we get properly independent assessments on impact of development? How do we decide and who decides that benefits of a development outweighs the importance of the biodiversity interest (G)? How will the council promote recommendations for household applications [4.26.12]?

Object

Representation ID: 25230

Received: 23/03/2021

Respondent: Denise Stanford

We fully support a policy which protects, enhances, restores and expands biodiversity and geodiversity. We have a concern over existing flora and fauna being under threat from new development - especially on Green Belt. Compensation for loss of existing biodiversity and offsetting should [4.26.17] be a last resort. How do we qualify and quantify where we need to exercise this last resort? Compensation seems to be an easy approach for developers who might make large profits from Green Belt sites. How do we protect these sites now and in the future? Do we have examples of proposals for how compensation works well and produces good results for communities? How do we get properly independent assessments on impact of development? How do we decide and who decides that benefits of a development outweighs the importance of the biodiversity interest (G)? How will the council promote recommendations for household applications [4.26.12]?

Object

Representation ID: 25442

Received: 23/03/2021

Respondent: Rebecca Stokes

We fully support a policy which protects, enhances, restores and expands biodiversity and geodiversity. We have a concern over existing flora and fauna being under threat from new development - especially on Green Belt. Compensation for loss of existing biodiversity and offsetting should [4.26.17] be a last resort. How do we qualify and quantify where we need to exercise this last resort? Compensation seems to be an easy approach for developers who might make large profits from Green Belt sites. How do we protect these sites now and in the future? Do we have examples of proposals for how compensation works well and produces good results for communities? How do we get properly independent assessments on impact of development? How do we decide and who decides that benefits of a development outweighs the importance of the biodiversity interest (G)? How will the council promote recommendations for household applications [4.26.12]?