Object

Representation ID: 21250

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.