Support

Representation ID: 6478

Received: 13/09/2021

Respondent: Gallagher Developments Group Limited

Agent: Barton Willmore

The principle of seeking biodiversity net gain is supported and is expected to be mandated nationally through the government’s Environment Bill if accepted by government and turned into an Act. The policy text also accounts for circumstances where net gain on site may be particularly challenging and instead requires enhancement or creation of off-site habitats. Further consideration does however need to be given to scenarios where landowners do not own sufficient off-site land and may need to consider contributions through biodiversity obligations or credits though financial payments as a last resort. We are uncertain what ’environmental net gain’ means in the context of this policy and if this requires more than ecological net gain measures. Paragraph 8 of the NPPF already defines the environmental objectives of sustainable development as protecting and enhancing our natural, built and historic environment; including making effective use of land, improving biodiversity, using natural resources prudently, minimising waste and pollution, and mitigating and adapting to climate change, including moving to a low carbon economy. Environmental net gain could therefore encompass several features leading to confusion in the interpretation and application of this policy and ultimately its soundness. The main focus of the policy appears to be on biodiversity and therefore we think the policy wording should be more closely aligned with this aspiration and replace ‘environmental net gain’ with ‘biodiversity net gain’. If the Council’s ambition is to secure greater levels of green infrastructure or green corridors to boost natural capital in the Borough, we would suggest this is best set out in a separate strategic policy, which is informed by a Green Infrastructure Study to identify areas of deficiency and opportunity. As this is a Borough-wide issue it requires a more planned, joined-up approach underpinned by evidence to maximise opportunities to improve the natural capital of the area, rather than relying on individual site appraisals that risk a more piecemeal, uncoordinated approach.