Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 4933

Received: 02/09/2021

Respondent: Kler Group

Agent: Cerda Planning Ltd

Representation Summary:

We do not raise any significant concerns in relation to Policy NE1, recognising the provisions of the forthcoming Environment Bill. However, the policy could be enhanced by making reference to applying the DEFRA metric as a means to benchmarking the baseline position with regard to environmental quality, and as a means to assessing the contribution that biodiversity enhancements make. This will provide for a consistent approach, and provide those bringing forward housing and other developments with certainty as to the approach to be taken.
As a separate observation, as drafted Policy NE1 makes reference to enhancing or creating off site habitats “in some circumstances”. The policy should be amended to make clear that off-site environmental net gain is an appropriate solution in all circumstances and may in fact lead to the creation of a greater environmental net gain than would otherwise be achieved on site – thus furthering the objectives behind the policy.