The principle of Policy BG/BG is supported, and it is also supported that the Councils have taken a proactive step to identifying habitat sites that smaller developments can contribute towards nature conservation programmes and projects.

However, the proposed policy sets a higher bar at 20% than the legal requirement of 10%, with the justification that the minimum legal requirement would not bring such great benefits for biodiversity. Further consideration needs to be given to the viability of schemes and deliverability of third level of ecology improvements to achieve the required level of 20%. The implications of this increased level of biodiversity net gain would potentially be to restrict small, medium, and large forms of development from coming forward in a timely manner.

Further consideration should be given too proposing a biodiversity net gain that meets the legal requirements of 10%.