Object

Representation ID: 43877

Received: 05/10/2021

Respondent: Taylor Wimpey

Agent: Pegasus

11.6 Policy LNR3 deals with the local recovery network and biodiversity net gain. It states that the Nature Recovery Network (NRN) is a major commitment in the Environment Bill which requires a Nature Recovery Strategy to be prepared locally and published for all areas of England. Policy ENV3 states all development shall deliver the local NRN Strategy in line with key principles. Amongst other things, it states that all development shall deliver a minimum of 10% net gain in biodiversity value. It also states that any exemption as to the need to provide biodiversity net gain will be set out in the relevant legislation and national guidance. Compensation will only be accepted in exceptional circumstances.
11.7 Paragraph 10.39 identifies that the Black Country authorities have commenced work on a Local Nature Recovery Network Strategy but this is yet to be concluded. The draft Nature Recovery Network opportunities map is included within Appendix 18 of the Plan but this again is in draft form. In view of the above there is considerable uncertainty as to whether the approach set in ENV3 will conclude in the manner envisaged, particularly where a number of the factors which will influence it are yet to be fixed. As a result, it provides an uncertain basis for the consideration of biodiversity and a more appropriate response would be for the Plan to follow the policy context set out in the NPPF on this matter. It would appear that the approach in the plan is making an attempt to predict a policy context which is at the early stages of development
and when the ultimate policy context may be significantly different.
11.8 In addition, the map produced at Appendix 18 is of such a small scale (1:125,000) as to make it unusable for many specific sites. Some of the strategies depicted by the mapping itself are difficult to understand. For example, the Fallings Park allocation is identified as a Core Expansion Zone 1 and Urban Matrix Recovery Zone 1 which recognises that the site is of lower ecological value but, due to its location, has the most potential to contribute towards a coherent ecological network and are a priority for investment in the restoration and creation of new habitats. Whilst Taylor Wimpey supports the potential for enhanced ecology and biodiversity as a consequence of the proposed development, this should not be at the expense of at the key objective to deliver the Neighbourhood Growth Area set out in the plan. This could be affected through the application of Policy ENV3 as it is currently drafted. In addition, much of the evidence relating to these matters has not yet been published and at present it remains an untested map produced by the Wildlife Trust for Birmingham and the Black Country and the local Environmental Records Centre. This is not a sufficient basis for what could be a significant Local Plan policy which has ramifications for strategic and local development.
11.9 In summary, Taylor Wimpey generally supports the approach to improving biodiversity in conjunction with development proposals. However, as set out above, further clarity is required in respect of what the NRN is, where it is and a strategy for its improvement.