Comment

Draft Black Country Plan

Representation ID: 23222

Received: 11/10/2021

Respondent: Heyfield Development

Agent: Harris Lamb

Representation Summary:

Policy ENV3 – Biodiversity net gain

This is a new requirement and will see the amount of land needed to achieve this increase. This will be true on brownfield and greenfield sites, with brownfields sites often being quite interesting from an ecological perspective for all manner of reasons. This also questions whether the 80% net area assumption is sound.