Object

Representation ID: 9069

Received: 12/11/2021

Respondent: Colmworth Parish Council

Agent: Troy Planning + Design

12. Biodiversity
Policy NE1 (Environmental Net Gain)
12.1. CPC is concerned that the policy wording of Policy NE1 (Environmental Net Gain) falls hort of what is required to achieve environmental net gain. As stated in best practice guidance published by CIRIA (2019), environmental net gain is defined as (our emphasis added) “development that leaves biodiversity in a better state than before, and an approach where developers work with local governments, wildlife groups, landowners and other stakeholders in order to support their priorities for nature conservation”. However, Policy NE1 (Environmental Net Gain) merely states that “proposals for major development should provide an environmental net gain (in accordance with government policy), which incorporates biodiversity net gain, through the following:
i) enhancement of the existing features of the site, particularly where these deliver significant levels of ecosystem services; or
ii) the creation of additional habitats on the site; or
iii) the linking of existing habitats to create links between ecological networks and where possible, with adjoining features”
12.2. The above policy (NE1) demonstrates a clear disregard and divergence from best practice guidance, as the built-in flexibility effectively allows developers to disregard the quality and innate importance of existing habitats on-site, in replacement for new habitats where there is no criteria to ensure that new habitats are of good-quality or are well-integrated and sensitively sited in respect of the local landscape and surrounding ecological networks. This omission could in practice lead to the degradation of local landscapes, where new developments lead to the continued fragmentation of local habitats. As such, Policy NE1 (Environmental Net Gain) does not comply with paragraph 174d) of the NPPF, as it cannot be demonstrated that Policy NE1 “contribute[s] to and enhance[s] the natural and local environment by […] minimising impacts on and providing net gains for biodiversity, including by establishing coherent ecological networks that are more resilient to current and future pressures”.