Comment

Representation ID: 23067

Received: 11/10/2021

Respondent: St Philips

Agent: Savills

Policy ENV3 – Nature Recovery Network and Biodiversity Net Gain

This Policy requires development to deliver the Local Nature Recovery Network Strategy and development is expected to deliver benefits appropriate to the zone they are located. However, the Black Country Strategy is not listed as a key evidence document and although a plan is provided at Appendix 18, it is unclear what development will be required to do in order to meet the requirements of Policy ENV3. Further clarity is sought on the requirements for ‘Core Expansion Zones’.
The Policy requires sites to achieve a biodiversity net gain of 10%. Any proposed uplift requested by the Council needs to accord with national policy unless evidence is provided to justify a different figure. As the Environment Bill has not yet been passed, the Council will need to monitor its position and amend the uplift requirement accordingly. Given the housing shortfall identified within the BCA and the national requirement to make efficient use of land, we consider that if suitable land is identified for off-site biodiversity improvements that should be supported to enable strategic allocations to be delivered as efficiently as possible.
We consider that Point 7 should refer to “where viable” in regards to providing compensation prior to development.