Comment

Draft Black Country Plan

Representation ID: 22283

Received: 21/01/2022

Respondent: Miss Jodi Stokes

Representation Summary:

Nature Recovery Network and Biodiversity Net Gain

9.3 Part 2 of draft Policy ENV3 (Nature Recovery Network and Biodiversity Net Gain) confirms that all development shall deliver a minimum 10% net gain in biodiversity value when measured against baseline site information. We agree with that this policy is reasonable, in line with paragraph 174 of the NPPF which requires 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. Paragraph 179 of the NPPF also sets out that plans should promote the conservation, restoration and enhancement of priority habitats, ecological networks and the protection and recovery of priority species; and identify and pursue opportunities for securing measurable net gains for biodiversity.