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.