Comment

Greater Cambridge Local Plan Preferred Options

Representation ID: 60328

Received: 13/12/2021

Respondent: Daniels Bros (Shefford) Ltd

Agent: DLP Planning Ltd

Representation Summary:

The proposed 20% Biodiversity Net Gain is not supported by robust evidence to justify the reasons to demonstrate that the higher level is appropriate or necessary in Greater Cambridge.

Full text:

NPPF paragraphs 174 - 188 outline how planning policy and decisions should contribute to and enhance the natural environment where possible.
The Environment Act 2021 introduced new mandatory requirements for provision of biodiversity net gain and outlines the requirement for developments to provide a minimum of 10% net gain, it is expected that this will apply to all developments from 2023 pending secondary regulations coming into force.
This policy outlines the approach to be taken to biodiversity and geodiversity impacts from development. It is proposed the development will be required to achieve a minimum of 20% biodiversity net gain and notes that net gain calculations should be submitted using Defra Biodiversity Metric 3.0 or any successor. The policy notes that onsite provision of biodiversity net gain will be sought were possible but that off-site habitat measures will also be considered where appropriate and where consistent with strategic aims of the Plan as set out in Policy BG/GI.
While the objectives of biodiversity enhancement are supported in principle the Councils’ proposed approach in terms of the levels of net gain sought is unsound: not justified and not consistent with national policy. The proposed approach not supported by robust evidence to justify the reasons to demonstrate that the higher level is appropriate or necessary in Greater Cambridge, also having regard to the policy costs of such an approach, relative to the Government’s position of what will be required nationally in future.