Comment

Representation ID: 10534

Received: 26/07/2022

Respondent: Barton Willmore

Draft Policy DM7 (Environmental Net Gain) requires proposals for major development to secure a minimum of 10% biodiversity net gain.
IM Land support the inclusion of the draft policy, which is considered to be consistent with National Policy (paragraph 174 (d) of the NPPF) which requires net gains for biodiversity to be provided, and the emerging Environment Act. It is also noted that the requirement within draft policy has been evidenced as being viable within the supporting Viability Assessment (April 2022), which demonstrates that it would not undermine the deliverability of the Local Plan overall.
A desk-based review of the Site has been carried out and suggests that the majority of the habitat comprises arable field, which is likely to be of relatively low ecological value. As such, a 10% net biodiversity gain is achievable.