7.3

Support

Representation ID: 6670

Received: 14/09/2021

Respondent: Stevington Parish Council

Section 7: Development Management policies Environmental Net Gain and biodiversity Net gain (7.30 to 7.37)
Environmental Net Gain and biodiversity Net gain (7.30 to 7.37)
If a net zero borough is to be created, one of the key activities will be delivery and demonstration of environmental net gain. Environmental net gain has wider implications than biodiversity net gain (it also include natural capital) and should therefore be specified rather than biodiversity net gain.
However, it is noted that there are dangers in using a habitat-based method biodiversity metric 2 or 3 to demonstrate biodiversity net gain in that it does not address living species (e.g., animals, insects). There is a danger, for example, that the habitat of the development area might be relocated and enhanced but important species lost. A detailed assessment should be made of all species present to ensure that they are not lost during development.
Due to the very high level of uncertainty in environmental net gain calculations, SPC would prefer the amount of net gain to be set at a much higher level than the 10% currently recommended in Government legislation. This should ideally be delivered on or within 5km of the development site.

Object

Representation ID: 6684

Received: 14/09/2021

Respondent: Cardington Parish Council

Agent: Cardington Parish Council

Para 7. Development management policies. 7.30 – 7.40 Natural environment policies.

We do not think that the Environmental and Biodiversity Net Gain approach, as currently formulated, treats the protection and enhancement of water resources adequately. Any further development of housing and the employment and transport infrastructure accompanying it will add to demands for water supplies, management of waste water and affect the pattern of flow of surface water to rivers, water courses and groundwater reserves. The additional infrastructure needed to satisfy the demand for water supply and manage waste water will additionally have an impact on water resources, particularly so in our already water-stressed region.

Cardington Parish Council has raised the need for a proper assessment of water resource impacts in every Local Plan consultation since 2002. With the evidence of steadily increasing climate change impacts on this crucial natural resource this is probably the last chance we have of recognising the issue and managing our response.

We urge that Local Plan 2040 either;
i) includes a detailed and authoritative analysis of what the impact of 25500 additional homes would be on the health of rivers, watercourses, groundwater resources and the agricultural and natural ecosystems that depend on them would be or
ii) admits that such an analysis has not been carried out and that the impacts of local Plan 2040 on water resources are unknown.