Greater Cambridge Local Plan: Proposed Submission
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Greater Cambridge Local Plan: Proposed Submission
Policy BG/BG: Biodiversity and geodiversity
Respondent: Trinity College
Representation Summary:
Policy BG/BG is unsound because it is not consistent with national policy. National Planning Policy Framework (17 August 2026) Policy N1(2) states that biodiversity net gain requirements above the statutory minimum should only apply to specific site allocations where justified and deliverable and should not apply to development exempt from the statutory BNG regime.
As drafted, Policy BG/BG imposes requirements beyond the statutory framework without these limitations. The policy should therefore be amended to align with N1(2), clarify exemptions, and refer to the statutory BNG framework in Schedule 7A of the Town and Country Planning Act 1990.
Change suggested by respondent:
The following modification is suggested point 2 be replaced with:
Major development must provide the statutory biodiversity net gain requirement in accordance with Schedule 7A of the Town and Country Planning Act 1990 (unless exempt from those requirements). Biodiversity net gain should be provided on-site where feasible and effective, or off-site where on-site opportunities have been demonstrated to be exhausted and this has been agreed by the Local Planning Authority. Requirements for biodiversity net gain in excess of the statutory minimum shall only apply to specific site allocations where justified and demonstrated to be deliverable
Full text:
Plan-Making Policy N1(2) of the National Planning Policy Framework (17 August 2026) states that development plans should only require biodiversity net gain in excess of the statutory requirement where this relates to specific site allocations and is fully justified and deliverable. It also states that local standards should not apply to categories of development that are exempt from the statutory biodiversity net gain regime.
As drafted, Policy BG/BG appears to impose biodiversity net gain requirements beyond the statutory framework without limiting them to specific allocations or providing the justification required by national policy. The policy therefore conflicts with the National Planning Policy Framework and fails the test of soundness that a plan must be consistent with national policy.
The policy should be amended to confirm that any biodiversity net gain requirements exceeding the statutory minimum apply only where justified through a specific site allocation policy. It should also make clear that development exempt from statutory biodiversity net gain requirements is not subject to additional local biodiversity net gain standards. Reference should also be made to the statutory biodiversity net gain framework contained in Schedule 7A of the Town and Country Planning Act 1990.
As a further point, if Policy BG/BG duplicates or materially departs from the national BNG framework, there is also an argument that it is inconsistent with the 2026 NPPF approach to avoiding duplication of national policies within development plans.
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