No

ID sylw: 98681

Derbyniwyd: 06/03/2025

Ymatebydd: Mrs Ginny White

Given the catastrophic decline of biodiversity in our county in recent decades I think the minimum of 10% Biodiversity Net Gain is an inadequate target. Local evidence shows that more than 10% is achievable in Warwickshire and I would like to see a target of 20% Net Gain as a minimum.

Yes

ID sylw: 98969

Derbyniwyd: 06/03/2025

Ymatebydd: Cotswold District Council

Support

No

ID sylw: 99060

Derbyniwyd: 06/03/2025

Ymatebydd: Mr Paul McCloskey

Again, not much wrong with what is written BUT....

10% Net Biodiversity Net Gain is not ambitious enough. It is far too easy for developers to downplay the existing state of a location ("just brash and scrub"), and then do very little but then claim there is a gain.

Please listen to this Podcast:
https://www.bbc.com/mediacentre/2022/the-big-green-money-show-series-two

This is Deborah Meaden talking with Mark Allan, Chief Executive of LandSec. He gives examples of Biodiversity net gain in the order of 200% to 300%! We should have a stretch target of 25% for any development. And EVERY site should provide Biodiversity net gain.

Yes

ID sylw: 99128

Derbyniwyd: 06/03/2025

Ymatebydd: Mr James Kennedy

In looking at whether BNG in excess of 10% is desirable the plan should draw on the experience of other local authorities where a higher rate has been approved. Measuring BNG is a process involving both evidence and judgement, and the authorities need to be confident that they have the resources and expertise to review and interrogate BNG plans put forward by developers. There is otherwise a danger that this becomes another box-ticking exercise rather than a genuine commitment to enhance biodiversity. SDC and WDC should start now to develop a scheme of offsite biodiversity units within their areas.

Other

ID sylw: 99191

Derbyniwyd: 06/03/2025

Ymatebydd: Mrs Jacqueline West

Target should be at least 15%.

Also very high weighting should be given to existing rare species eg Birds on the conservation red list species. Their roosting & breeding sites and feeding habitat should not be removed by developments. This is particularly important for rare species that are not locally abundant, indicating this a specific site with the right conditions for them to thrive.

Other

ID sylw: 99213

Derbyniwyd: 06/03/2025

Ymatebydd: MPTL

Asiant : Harris Lamb

The policy makes a reference to the potential requirement for in excess of 10% BNG. This has the potential undermine the viability of sites. BNG is a significant development cost both financial and in terms of land take. It is essential that any policy of this nature are viability tested

No

ID sylw: 99327

Derbyniwyd: 06/03/2025

Ymatebydd: Vistry Strategic Land - Wellesbourne

We are generally supportive of requirements of Draft Policy Direction 38, however, it is noted that the Policy makes reference to the SWLP exploring evidence to seek higher percentage of BNG than the statutory 10% requirement. There is no national policy requirement for this. It is without basis. Any proposal of this nature must be viability tested.
BNG provision can have significant implications on the viability of development sites and their capacity. We object to any proposal to seek greater than 10% BNG.

Yes

ID sylw: 99662

Derbyniwyd: 06/03/2025

Ymatebydd: Ms Gillian Padgham

agree

No

ID sylw: 99736

Derbyniwyd: 06/03/2025

Ymatebydd: Mr Richard Stone -Johnston

Biodiversity Net Gain, while well-intentioned, is flawed in its implementation. In the short term, development projects that promise biodiversity gains often lead to significant habitat destruction, which can be devastating for local ecosystems. The promised restoration or compensation measures take years, if not decades, to become fully effective, and may never truly replace the intricate biodiversity lost. This delay in recovery threatens the survival of many species and risks permanent ecological damage that undermines long-term environmental sustainability.

No

ID sylw: 99927

Derbyniwyd: 06/03/2025

Ymatebydd: Mr Steven Simpson

I am not satisfied with the councils’ intention to ‘explore opportunities’ for higher than the bare minimum of 10% Biodiversity Net Gain.

Local evidence through planning applications shows that more than 10% BNG is achievable in Warwickshire, and the Plan states that they are aiming to link with local priorities, so a greater target should be delivered. A number of other Councils such as Cornwall Council have already got plans through Examination with 20% net gain.

Yes

ID sylw: 100047

Derbyniwyd: 06/03/2025

Ymatebydd: Welford on Avon Parish Council

A laudable ambition but its abused at the moment and therefore doesnt achieve its intended goals.

There needs to be a better way to ensure complance.

include some simple principals eg: take a tree out and you have to replace it 2 for 1.

Yes

ID sylw: 100420

Derbyniwyd: 06/03/2025

Ymatebydd: Mr Adrian Parsons

I absolutely agree with the approach laid out

No

ID sylw: 100473

Derbyniwyd: 06/03/2025

Ymatebydd: Mrs Lorraine Grocott

Purchasing biodiversity units as a method of offsetting carbon footprint will never improve biodiversity. Focus should be on preserving areas of higher biodiversity already in existence rather than allowing development on these areas.. There is a concern that BNG units present net gain on paper, but not in practice.

No

ID sylw: 100712

Derbyniwyd: 07/03/2025

Ymatebydd: Drayton Manor Farms Ltd

Asiant : Stansgate Planning

No.
Meeting the statutory 10% BNG requirement is challenging and causes delays and viability
concerns to many developments but is unavoidable as a national validation requirement. Draft
Policy Direction 38 indicates the Council’s will explore evidence to adopt a higher percentage to
achieve greater biodiversity benefits. The inclusion of a higher figure is not supported.
National planning guidance states that a higher figure must only be adopted on either an area wider
basis or for specific allocations if it is fully justified. As set out in Framework Paragraph 006
Reference ID: 74-006-20240214 fully justified means evidence of:
• local need for a higher percentage
• local opportunities for higher percentage
• impacts on viability for development
As yet the Council has failed to provide evidence to support a higher figure and on the basis of
knowledge of the industry it seems highly unlikely such justification could be provided. The policy
proposal must therefore be dropped.
If work towards a higher BNG figure is progressed then detailed consideration should be given as
to how any such policy could be implemented – particularly in respect of viability, without undue
pressure on applicants to undertake lengthy and complicated viability assessments

No

ID sylw: 100745

Derbyniwyd: 07/03/2025

Ymatebydd: Gladman Developments

Gladman support the aim of a minimum of 10% BNG over the pre-development site value, measured by the DEFRA Statutory Biodiversity Metric, in alignment with the Environment Act 2021.

However, Gladman do not consider it sound for the Council to explore the idea of seeking a higher percentage of BNG above the statutory 10% on new development proposals. Paragraph 006 of the PPG is clear that requirements beyond 10% BNG must be clearly justified, and evidence demonstrating the implications of a higher BNG percentage must be provided. The SWLP should provide certainty for developers with a fixed figure. The wording of criteria two doesn't reflect national policy which does not give the option of seeking less than 10% BNG.

Higher requirements would likely require extensive areas of land to be removed from the potential developable area and inefficient use of land. The provision of BNG can be incredibly costly and impact site viability as a result. 10% BNG ensures developments leave more biodiversity than previously the case and is not overly burdensome on developers. BNG must not prevent, delay or reduce housing delivery as this will hamper provision of much-needed housing (including affordable housing) and other social/community facilities required.

No

ID sylw: 100794

Derbyniwyd: 07/03/2025

Ymatebydd: Mr Garry Rollason

It is difficult to see haw the scale of development envisaged in the plan could generate a BNG as all the new settlement sites will result in a permanent loss of biodiversity and environmental resilience - offsetting this loss by obtaining "credits" elsewhere does not make ecological or financial sense. In any event requiring a BNG of 10% does not go far enough - South Warwickshire should have the ambition to go further especially where Green Belt land is built upon. In terms of the locational hierarchy developers should not be allowed to buy offsite units outside Warwickshire.

No

ID sylw: 100843

Derbyniwyd: 07/03/2025

Ymatebydd: Friends of Radfords Green Environment (FORGE)

Local evidence through planning applications shows that more than 10% BNG is achievable in Warwickshire, and the Plan states that they are aiming to link with local priorities, so a greater target should be delivered. A number of other Councils such as Cornwall Council have already got plans through Examination with 20% net gain.

No

ID sylw: 100911

Derbyniwyd: 07/03/2025

Ymatebydd: Vistry Strategic Land - Wellesbourne

We are generally supportive of requirements of Draft Policy Direction 38, however, it is noted that the Policy makes reference to the SWLP exploring evidence to seek higher percentage of BNG than the statutory 10% requirement. There is no national policy requirement for this. It is without basis. Any proposal of this nature must be viability tested.
BNG provision can have significant implications on the viability of development sites and their capacity. We object to any proposal to seek greater than 10% BNG.

Yes

ID sylw: 101010

Derbyniwyd: 07/03/2025

Ymatebydd: Mrs Stacey Wall

Prioritisation of green spaces and nature areas on new build estates

Other

ID sylw: 101078

Derbyniwyd: 07/03/2025

Ymatebydd: H Crook

10% too low
New housing developments in south warwickshire already plant trees and hedging thereby "fulfilling their environmental requirements". But are just bypassing the requirements:
These trees and hedging are often non-native so do not help native wildlife.
The plantings are usually done out of planting season and die
The plantings are not watered and die.
Long Marston airfield housing site for an example.
The 10% must be on the site, or locality, otherwise local wildlife dies off and there will also be a negative impact on physical and mental health of human population.

No

ID sylw: 101117

Derbyniwyd: 07/03/2025

Ymatebydd: Rowington Landowner Consortium

Asiant : Knight Frank LLP

The policy's alignment with national legislation is acknowledged, and while pursuing biodiversity gains beyond statutory requirements is commendable, robust evidence is necessary to justify such increases. A positively worded policy should support the benefits of exceeding the 10% minimum BNG. However, mandating a higher BNG could conflict with other material considerations whereby sites may be unable to achieve this. It is therefore advisable not to elevate local requirements without sufficient robust justification.

Yes

ID sylw: 101221

Derbyniwyd: 07/03/2025

Ymatebydd: Hallam Land Management Limited

Asiant : Mr Jack Barnes

This policy reflects the national requirements with regards to Biodiversity Net Gain.

No

ID sylw: 101328

Derbyniwyd: 07/03/2025

Ymatebydd: Ashberry Strategic Land Ltd

Asiant : Stansgate Planning

Meeting the statutory 10% BNG requirement is challenging and causes delays and viability concerns to many developments but is unavoidable as a national validation requirement. Draft
Policy Direction 38 indicates the Councils will explore evidence to adopt a higher percentage to achieve greater biodiversity benefits. The inclusion of a higher figure is not supported.

NPPF Paragraph 006 states that a higher figure can only be adopted if their is evidence of local need and local opportunities for a higher percentage and assessment of impacts on viability. Based on knowledge of the industry it's highly unlikely such justification could be provided. This proposal should therefore be dropped. If progressed there will need to be detailed consideration on how it could be implemented without undue pressure on applicants to undertake lengthy and complicated viability assessments.

No

ID sylw: 101395

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Strategic Land / Ashberry Strategic Land

Asiant : Marrons

This policy suggests that evidence will be explored to seek a higher percentage of Biodiversity Net Gain above the statutory 10% requirement. Bellway / Ashberry Strategic Land disagree with this approach and would suggest that the policy remains in line with statutory national guidance. The Council need to consider the implications of higher Biodiversity Net Gain on viability, site yields and the ability for this be delivered efficiently.

Yes

ID sylw: 101444

Derbyniwyd: 07/03/2025

Ymatebydd: Alderley Holdings Trust

Asiant : Mr Jack Barnes

This policy reflects the national requirements with regards to Biodiversity Net Gain.

Yes

ID sylw: 101534

Derbyniwyd: 07/03/2025

Ymatebydd: Hallam Land

Asiant : Marrons

This policy reflects the minimum 10% national requirements with regards to Biodiversity Net Gain. If a higher percentage is sought, it will need to be justified with particular reference to its impacts on the capacity of sites and viability.

No

ID sylw: 101600

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Homes Ltd

Asiant : Stansgate Planning

The inclusion of a higher figure is not supported.
National planning guidance states that a higher figure must only be adopted on either an area wider basis or for specific allocations if it is fully justified. As set out in Framework Paragraph 006 Reference ID: 74-006-20240214 fully justified means evidence of:
• local need for a higher percentage
• local opportunities for higher percentage
• impacts on viability for development
As yet the Council has failed to provide evidence to support a higher figure and on the basis of knowledge of the industry it seems highly unlikely such justification could be provided. The policy proposal must therefore be dropped.
If work towards a higher BNG figure is progressed then detailed consideration should be given as to how any such policy could be implemented – particularly in respect of viability, without undue pressure on applicants to undertake lengthy and complicated viability assessments

Yes

ID sylw: 101603

Derbyniwyd: 07/03/2025

Ymatebydd: Ms Zoe Leventhal

Support. In looking at whether BNG in excess of 10% is desirable the plan should draw on the experience of other local authorities where a higher rate has been approved. Measuring BNG is a process involving both evidence and judgement, and the authorities need to be confident that they have the resources and expertise to review and interrogate BNG plans put forward by developers. There is otherwise a danger that this becomes another box-ticking exercise rather than a genuine commitment to enhance biodiversity. SDC and WDC should start now to develop a scheme of offsite biodiversity units within their areas.

No

ID sylw: 101613

Derbyniwyd: 07/03/2025

Ymatebydd: Mrs Anne Teed

The councils should be aiming higher than the 10% BNG. A greater target should be included, local planning applications show this is possible. Other councils, such as Cornwall, have 20%. Our councils should be aiming for a higher BNG.

Yes

ID sylw: 101685

Derbyniwyd: 07/03/2025

Ymatebydd: Mr Bart Slob

I support the approach laid out in this Draft Policy, which mandates that development proposals must achieve at least a 10% BNG, with the potential for a higher percentage based on local needs. This policy aligns with national requirements and ensures that biodiversity is enhanced as part of the development process. However, in areas like SG04, which may have significant ecological value, it is essential that any proposed development prioritizes on-site biodiversity enhancements. Off-site biodiversity units should only be considered when on-site solutions are not feasible, and these should be consistent with the Local Nature Recovery Strategy.