Object

Representation ID: 8752

Received: 29/09/2021

Respondent: Bedfordshire Hospitals NHS Foundation Trust

Agent: Barton Willmore

7.1 The Trust does not have any comments except in relation to Draft Policy NE1,
Environmental Net Gain.

7.2 The principle of seeking biodiversity net gain is supported and is expected to be mandated nationally through the government’s Environment Bill. 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. However, we consider that further consideration needs 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 as a last resort.

7.3 We consider that 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, potentially leading to confusion in the interpretation and application of this policy and ultimately its soundness. This will enviably lead to issue for decision makers when trying to apply the policy to developments.

7.4 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. The term ‘environmental net gain’ should be replaced with ‘biodiversity net gain’.