Consultation Question 40

Object

Representation ID: 26869

Received: 24/03/2021

Respondent: Sarah Harrison

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: 26898

Received: 24/03/2021

Respondent: Elizabeth Elkington

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: 26927

Received: 24/03/2021

Respondent: Ella Hyde

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: 26958

Received: 24/03/2021

Respondent: Samantha Waddington

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: 26987

Received: 24/03/2021

Respondent: Tim Price

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: 27019

Received: 24/03/2021

Respondent: Rosie Eccles

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: 27048

Received: 24/03/2021

Respondent: Clare Butland

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: 27077

Received: 24/03/2021

Respondent: Nabil Basharat

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: 27130

Received: 24/03/2021

Respondent: Ian Sunderland

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: 27159

Received: 24/03/2021

Respondent: Marianne Clarke

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: 27188

Received: 24/03/2021

Respondent: Carole Wheeler

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: 27217

Received: 24/03/2021

Respondent: Julie Sunderland

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: 27246

Received: 24/03/2021

Respondent: Gary Scott

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: 27278

Received: 24/03/2021

Respondent: Ms Jane 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: 27307

Received: 24/03/2021

Respondent: Mr Alan Lovell

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: 27336

Received: 24/03/2021

Respondent: Marjorie Rogan

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: 27365

Received: 24/03/2021

Respondent: Paul Cryer

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: 27394

Received: 24/03/2021

Respondent: Wendy Barton

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: 27423

Received: 24/03/2021

Respondent: Mr Richard Bardsley

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: 27452

Received: 24/03/2021

Respondent: Paul Warren

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: 27574

Received: 24/03/2021

Respondent: Danny Thompson

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: 27650

Received: 24/03/2021

Respondent: Persimmon Homes (West Yorkshire)

Agent: Lichfields

Whilst the achievement of biodiversity net gain as required by draft Policy EN3 is supported in principle, until such time as the Environment Bill clarifies the requirement for biodiversity net gain it is recommended that part H of this policy be amended to refer to all development delivering a measurable net gain ‘where practical to do so’, so as not to undermine the development of otherwise sustainable sites.

Section A: In order to provide certainty, the Wildlife Habitat Network mentioned in the table should be defined on the policies map. The table states that the network will include designated and undesignated habitats, but does not describe what will constitute either elements. Without further explanation ‘undesignated sites of high conservation value’ has no meaning as it is a value judgement of whether a site is of ‘high’ conservation value or not.
Section B 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. This is incorrect. 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 per se). In order to be compliant with the Habitat Regulations, 2017 (as amended) 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 we have suggested for SP11 and the HRA of the draft Local Plan will modify the application of Section B of the policy.
Section C: There is no legal requirement for impacts upon an 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.
Section D: The Wildlife Habitat Network need to be defined in order to provide certainty for decision making (see also paragraph 2.81). The policy does not allow sufficient flexibility for mitigation and compensatory measures and should be reworded to reflect this.
Section E. The policy seems to refer to the movement of any species including those with poor dispersal mechanisms? Perhaps the policy should state “or impair the functioning of the Network by preventing movement of species” that are relevant to that Network.
Section I should not reference the Environment Bill, because there is no certainty as to the Bill’s final form or content.
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 compensation in all cases. There is also no legal requirement to provide BNG CBMDC Draft Local Plan Review Persimmon Homes West Yorkshire 10 compensation as ‘a preference for those in the immediate vicinity’ and this should also be removed.
Section J: What are ‘local biodiversity priorities’? If the policy is referring to specific species and habitats such as those defined by Local Biodiversity Action Plans, the NERC Act, 2006, or Birds of Conservation Concern etc. then this should be specified.
Section J: Biodiversity net gain is a habitat based system and while there will inevitably be benefits to species the mechanism is not targeted to the conservation of individual species. We suggest that the last sentence of this policy be deleted as the BNG mechanism does not address species conservation.
Section M is unclear and ambiguously worded. BNG is a tool for gain in biodiversity not ‘well-being’. It is also not clear how this policy will be implemented in practice.
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: 27699

Received: 24/03/2021

Respondent: Peter Cartwright

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: 27733

Received: 24/03/2021

Respondent: Mrs Ann Todd

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: 27806

Received: 24/03/2021

Respondent: Richard Briggs

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: 27837

Received: 24/03/2021

Respondent: Claire Shouler

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: 27901

Received: 23/03/2021

Respondent: Samantha Armitage

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: 27922

Received: 24/03/2021

Respondent: E.M. Farming & Leisure Ltd

Agent: McLoughlin Planning

EMFL consider that the Council should not deviate from the Government’s proposals on biodiversity gain as set out in the Environment Bill which will set out the most appropriate approach to biodiversity net gain. 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

Object

Representation ID: 28200

Received: 24/03/2021

Respondent: Sarah Lucas

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: 28290

Received: 24/03/2021

Respondent: Stephen Mould

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]?