Comment
Greater Cambridge Local Plan Preferred Options
Representation ID: 60159
Received: 10/12/2021
Respondent: Home Builders Federation
The requirement for a 20% net gain in biodiversity is not sound. No robust justification has been provided as to why the Greater Cambridge area is any different to the rest of the country and should set a higher requirement for net biodiversity gains from new development. If Government considers 10% sufficient to mitigate the impact of new development in future, then this should also be an appropriate level of net gain for the Greater Cambridge area. It is important to recognise that the Environment Act does not set this as a minimum and at present there is no suggestion that in future policy will allow for a higher requirement to be set in local plans.
The HBF also has concerns that the impact of a 20% requirement has not been fully considered. A 20% requirement will have a more considerable cost impact than as is suggested in the viability assessment and one that could impact on the deliverability of some sites. Therefore, we recommend that the policy is amended to ensure that it reflects the approach established in the Environment Act that requires a 10% net gain in biodiversity.
The requirement for a 20% net gain in biodiversity is not sound. No robust justification has been provided as to why the Greater Cambridge area is any different to the rest of the country and should set a higher requirement for net biodiversity gains from new development. If Government considers 10% sufficient to mitigate the impact of new development in future, then this should also be an appropriate level of net gain for the Greater Cambridge area. It is important to recognise that the Environment Act does not set this as a minimum and at present there is no suggestion that in future policy will allow for a higher requirement to be set in local plans.
The HBF also has concerns that the impact of a 20% requirement has not been fully considered. A 20% requirement will have a more considerable cost impact than as is suggested in the viability assessment and one that could impact on the deliverability of some sites. Therefore, we recommend that the policy is amended to ensure that it reflects the approach established in the Environment Act that requires a 10% net gain in biodiversity.