Object

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

Representation ID: 6685

Received: 14/09/2021

Respondent: Cardington Parish Council

Agent: Cardington Parish Council

Representation Summary:

Policy NE1 – Environmental net gain.

This policy is fundamentally flawed in that it proposes to deliver Environmental Net Gain on a site-by-site management basis on the unfounded assumption that the end result of 25500 houses in 2040 can be achieved with an Environmental Net Gain.

As the Policy admits, achieving Environmental Net Gain may mean enhancing or creating off-site habitats. Other important environmental issues, which should also be listed in the Policy such as maintaining or enhancing water permeability, managing surface run-off and treatment of waste water, are also likely to require off-site measures. Similarly, building and infrastructure development standards cannot be left to site-by-site decisions but must be specified as a result of analysing what standards are necessary for the total development target.

The Plan must offer evidence that 25500 houses can be achieved with Environmental Net Gain and the protection of crucial resources such as water, together with minimum standards, specified through Policy NE1, that every development must comply with in order to achieve this. If it does not do this, a site-by-site management process alone runs the risk of demonstrating, sometime before 2040, that Environmental Net Gain and protection of water resources can only be achieved within a housing target less than 25500.