Comment

Representation ID: 23336

Received: 11/10/2021

Respondent: Bloor Homes

Proposed Policy ENV3 requires all development to deliver a minimum 10% net gain in biodiversity value when measured against baseline site information. BHL are aware of the Government’s proposals on biodiversity net gain as set out in the Environment Bill. This legislation (when passed through parliament) contains a general duty to enhance biodiversity which will apply to the planning system by insertion of a new section 90A within the Town Country Planning Act 1990. The new section 90A will make it a requirement for development in England to be required to ensure the biodiversity attributable to the development exceeds the
predevelopment value by 10%. This must be measured using a recognised biodiversity metric i.e. DEFRA’s Biodiversity Metric 3.0 that was introduced in July 2021. BHL agree with the Government, that the figure of 10% strikes the right balance in providing certainty in achieving environmental outcomes whilst not prohibiting the deliverability of development. Therefore, BHL consider that the BCA should not deviate from the Government’s proposals and should not specify a requirement above 10%. BHL request that the words “a minimum” are deleted from Policy ENV3.

BHL notes that the Government will introduce exemptions applicable to the most constrained types
of development which will be set out in secondary legislation and as such, BHL considers the use of “all development” is premature. Sites without reasonable opportunities to achieve biodiversity net gain should not be delayed through inflexible and prescriptive requirements.