Support

Representation ID: 7235

Received: 17/09/2021

Respondent: L&Q Estates Limited

Agent: Barton Willmore

It is unclear 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. This will inevitably lead to issues for decision makers when trying to apply the policy to developments.
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’ which is fully supported by the Promoters.
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.