Comment

Representation ID: 21349

Received: 11/10/2021

Respondent: William Davis Homes

Agent: Define Planning and Design Ltd

POLICY ENV3 – NATURE RECOVERY NETWORK AND BIODIVERSITY NET GAIN
WDH notes that Policy ENV3 requires new developments to deliver a 10% biodiversity net gain. Whilst the intention of that policy is understood, a 10% net gain is not yet required by national policy or legislation (given that the Environment Bill has not yet been passed), and as such that requirement will need to be evidenced and justified. Rather, it would be more suitable for Policy ENV3 to require a biodiversity net gain “in accordance with the most up-to-date national policy or legislation” both to ensure consistency with national guidance and to future-proof the policy.
Policy ENV3 states that off-site compensation is only to be accepted in “exceptional circumstances.” That is too high of a threshold for such a policy (and is to be used for matters such as Green Belt release) and that, notwithstanding that, further guidance in relation to the mechanism for delivering biodiversity compensation should be included in the policy or supporting text to provide developers with certainty on that process.