Comment

Representation ID: 21249

Received: 11/10/2021

Respondent: Newlands Developments

Biodiversity Net Gain
NPPF Paragraph 32 advises that Local Plans should address relevant environmental objectives, including opportunities for net gains. Where significant adverse impacts are unavoidable, suitable mitigation measures should be proposed (or, where this is not possible, compensatory measures should be considered). Moreover, Paragraph 174 advises that planning policies and decisions should contribute to and enhance the natural and local environment by minimising impacts on and providing net gains for biodiversity, including by establishing coherent ecological networks that are more resilient to current and future pressures.

As such, it is considered that draft Policy ENV3 (Nature Recovery Network and Biodiversity Net Gain) is not consistent with national policy as it requires all development to deliver a minimum 10% net gain in biodiversity value when measured against baseline site information. The NPPF places no requirement on development proposals to deliver a notional target of a 10% net gain. It is therefore considered that draft Policy ENV3 should be amended to simply require all development proposals to achieve a biodiversity net gain.

Draft Policy ENV9 (Design Quality) provides guidance on design standards and principles to be assessed and included within design and access statements. Part 1(d) of Draft Policy ENV9 is of particular relevance to employment developments as it encourages developments to consider crime prevention measures and Secured by Design Principles. We support Policy ENV9 in principle, as this policy seeks to ensure that developments are designed to the highest possible standards.