Support

Draft Black Country Plan

Representation ID: 22426

Received: 11/10/2021

Respondent: Mr Maurice Sanders

Agent: Avison Young

Representation Summary:

Policy ENV3 – Nature Recovery Work and Biodiversity Net Gain
Our Client supports the principal of net gain and the 10% target which will shortly be mandated
nationally. It also supports the principal of calculating net gain using the national Biodiversity
Metric, assuming the Draft Plan is referring to the Biodiversity 3.0 metric provided by DEFRA, to
ensure a consistency of approach between Local Authorities. The policy should be updated to
make specific reference to this metric.