Consultation Question 40

Comment

Representation ID: 29117

Received: 24/03/2021

Respondent: Environment Agency

We strongly encourage you to consider at the earliest opportunity how you will incorporate net gain within your Local Plan policies and Supplementary Planning Documents. You will need to consider any supporting evidence requirements.

Biodiversity net gain policy needs to be founded on a good yet proportionate evidence base. A good evidence base puts you in a strong position to shape the subsequent direction of policy. We encourage you to use the best available local environmental data. There is also an opportunity to consider Nature Recovery Strategies within this evidence gathering and wider natural capital goals.

Support

Representation ID: 29189

Received: 24/03/2021

Respondent: Environment Agency

We support the current content of Policy EN2 – in particular the references to BNG and the use of the DEFRA Biodiversity Metric; and also the protection and strengthening of the Wildlife Habitat Network.

We would recommend that any policy referencing this includes the term ‘measureable net gain’ as per the wording in the revised NPPF2.

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.

Object

Representation ID: 29223

Received: 23/03/2021

Respondent: Rachel Wood

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: 29576

Received: 23/03/2021

Respondent: Harvey Bosomworth

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: 29616

Received: 17/03/2021

Respondent: Mr Mark Summerson

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: 30015

Received: 23/03/2021

Respondent: Daniel Spencer

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: 30096

Received: 23/03/2021

Respondent: Mrs Savia Lorain Hughes

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: 30179

Received: 23/03/2021

Respondent: Catherine Terry

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]?