BASE HEADER

No

ID sylw: 108751

Derbyniwyd: 19/03/2025

Ymatebydd: King Henry VIII Endowed Trust (Warwick)

Asiant : Savills

We object to Draft Policy Direction 39 on the basis that evidence has yet to be provided to justify the inclusion of an Environmental Net Gain (ENG) policy, nor any information about how such a policy would function in practice. To our knowledge, there are no other examples of adopted Local Plan policies requiring ENG or any well-developed metric for measuring ENG. Developing an ENG policy from this starting point could lead to additional delay to the adoption of the SWLP due to the amount of evidence base which would need to be collected, in addition to developing a metric through which to quantify gains.
We also consider that the inclusion of an ENG policy could place a further financial burden on developers in addition to the statutory requirement to deliver 10% Biodiversity Net Gain, as well as other requirements to provide on-site public open space, green infrastructure and Sustainable Drainage Systems. We remain concerned that the introduction of a further requirement could impact viability of development sites and lead to a further reduction in net developable areas.