Comment

Representation ID: 9959

Received: 28/07/2022

Respondent: Bedfordia Developments Ltd and L & Q Estates Ltd

Agent: Barton Willmore

The principle of seeking biodiversity net gain is
supported. We welcome flexibility in the wording of this policy which reflects the ability
to provide net gain offsite should it not be possible on site. The policy should be further
updated for the purchase of biodiversity net gain credits as a ‘last resort’, the conditions
for which should be defined. This would be consistent with the Environmental Bill.
As raised in our Regulation 18 consultation representations, the policy in the blue box
focuses primarily upon biodiversity net gain. However, it requires the following:
“Planning applications should demonstrate how net
biodiversity and net environmental gain will be achieved
through the product ion of a supporting statement that considers the contribution the proposal could make to the
borough ’s natural capital.”
In the pretext to the policy under point 6.62, the following sum example is provided:
Environment a l net gain = biodiversity net g in + natural capital gain
This appears inconsistent with the policy which suggests the approach is: environmental
net gain + biodiversity net gain = natural capital gain.
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.
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.