Yes

ID sylw: 103923

Derbyniwyd: 07/03/2025

Ymatebydd: Ms Margaret Halligan

Agree

No

ID sylw: 103969

Derbyniwyd: 07/03/2025

Ymatebydd: Mr Amarjit Gill

This should be a minimum 50% and requires more robust evidence of its actual benefit in practice not just theoretical

No

ID sylw: 104025

Derbyniwyd: 07/03/2025

Ymatebydd: Ms Camille Newton

Given Warwick District Councils Biodiversity Action Program to halt loss in the district, a greater than 10% BNG figure should be used, in line with an increasing number of Local Authorities demanding higher than 10%. A higher percentage will balance out developments, for which offsetting is sought outside the district, although the council should adopt a policy where biodiversity net gain is met purely within the district. Development density should be balanced against biodiversity improvements, large developments should not have the excuse that they cant meet BNG targets onsite, if the reason for this is they are maximising development instead.

No

ID sylw: 104162

Derbyniwyd: 07/03/2025

Ymatebydd: Mrs Clare Kimpton

Again this seems very weak only going for minimum target

Yes

ID sylw: 104265

Derbyniwyd: 07/03/2025

Ymatebydd: Mr Stephen Norrie

I note the intention to pursue evidence for increasing biodiversity net gain targets above the nationally mandated 10% and would encourage you to do so.

I have mixed feelings about the use of biodiversity credits, but the approach adopted here will at least tend to localise purchases, making achievement more credible. To allow Councils (and members of the public) to monitor whether credits are actually underpinned by real achievements, companies should be required to maintain records in a publicly accessible place, in an easily interpreted format.

Yes

ID sylw: 104459

Derbyniwyd: 07/03/2025

Ymatebydd: South Warwickshire Foundation trust

We agree and support this approach

No

ID sylw: 104585

Derbyniwyd: 07/03/2025

Ymatebydd: Elizabeth White

Biodiversity loss in Bishop’s Tachbrook funded the beautiful Alscot Estate south of Stratford, not noticeably bereft of biodiversity!

Any biodiversity offset should remain ‘within the Local Planning Authority area where the impact occurs’.

‘Buying off-site biodiversity units’ in compensation for eg. building over a biodiverse Zone 3 river Floodplain is absurd!

No

ID sylw: 104670

Derbyniwyd: 07/03/2025

Ymatebydd: Mr Neal Appleton

Purchasing BNG credits is the favoured approach. Plans, particularly for small-scale development, rarely accommodate BNG on-site. Densification strategies often work against incorporating BNG on-site.

Yes

ID sylw: 104838

Derbyniwyd: 07/03/2025

Ymatebydd: Miss Ann Colley

agree

No

ID sylw: 104841

Derbyniwyd: 07/03/2025

Ymatebydd: Dr Susan Hood

An intention to ‘explore opportunities’ for higher than the bare minimum of 10% Biodiversity Net Gain is not satisfactory. Local evidence through planning applications shows that more than 10% biodiversity net gain is achievable in Warwickshire, and the Plan states that they are aiming to link with local priorities, so a greater target should be delivered. It is especially important that more rural areas optimise their contribution to biodiversity net gain.

Yes

ID sylw: 104994

Derbyniwyd: 07/03/2025

Ymatebydd: Fern Arnold

Agree with 10%+ BNG on site. Concerned about the ten percent being off site. Is there a national register of this land? Is it possible that a developer uses same land multiple times for different developments? How do we know the land is maintained and not developed in the future.
Also in the tender process is it on cost only? Do you consider the developers past environmental record or what they say they can add to the development. Not just bng and wildlife corridors but future proofing eco homes.

Yes

ID sylw: 105011

Derbyniwyd: 07/03/2025

Ymatebydd: Ms Susan Ingleby

Yes

Other

ID sylw: 105116

Derbyniwyd: 27/02/2025

Ymatebydd: St Philips

Asiant : Lichfields (Birmingham)

St Philips understand that Local Plans must address economic, social, and environmental objectives, including a 10% biodiversity net gain (BNG) as mandated by the Environment Act 2021. St Philips supports biodiversity offsetting but is concerned that the SWAs might propose a higher BNG percentage without adequate justification. The SWLP lacks sufficient evidence to support such an increase and must include a Viability Assessment considering BNG's impact on site viability. Additionally, duplicating the Environment Act's requirements in the SWLP seems unnecessary, as it would not serve a clear purpose.

No

ID sylw: 105304

Derbyniwyd: 28/02/2025

Ymatebydd: Warwickshire Wildlife Trust

No. Warwickshire Wildlife Trust is 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.

No

ID sylw: 105783

Derbyniwyd: 07/03/2025

Ymatebydd: Wates Developments Ltd

Asiant : Savills

We object to Draft Policy Direction 38 and consider that the Councils should not seek to require Biodiversity Net Gain (BNG) in excess of the 10% statutory requirement. We consider that the 10% BNG requirement is an important statutory requirement which should be provided in line with existing legislation. However, Planning Practice Guidance1 states that any requirement for BNG in excess of 10% will require robust evidence as to why a further requirement is necessary and that viability will not be impacted. Such evidence has yet to be provided by the Councils and therefore we object on this basis. In some cases, seeking more than 10% BNG could make sites unviable or less sustainable by not maximising development opportunities and also lead to larger land areas being released for the same quantum of development.

Other

ID sylw: 106214

Derbyniwyd: 07/03/2025

Ymatebydd: Cala Homes (Cotswolds)

Asiant : Lichfields (London)

Cala supports the requirement for development proposals to achieve a minimum 10% Biodiversity Net Gain as determined by the DEFRA statutory biodiversity metric. This aligns with Schedule 7A of the Town and Country Planning Act 1990 and NPPF paragraphs 187(d) and 192. Cala does not support the statement that the SWLP will explore evidence to go above the statutory 10% requirement. This is against PPG ID 74-006. Clear justification and detailed evidence on viability would be required to deviate away from the PPG. Sites are facing increasing build costs which is impacting viability of many sites. BNG policy needs to ensure that it does not limit ability of developments to come forward and flexibility must be provided in all circumstances.

Other

ID sylw: 106374

Derbyniwyd: 07/03/2025

Ymatebydd: West Midlands Housing Association Planning Consortium

Asiant : Tetlow King Planning

Draft Policy Direction 38 requires all new development proposals (unless exempt) must achieve a minimum of 10% BNG on-site or as a last resort, purchase statutory biodiversity credits from the government.
The WMHAPC would welcome the production of a BNG supplementary planning document and/or a further implementation note/guidance following the adoption of the Local Plan for developers to understand the costs of the mandatory BNG requirement such the purchase of credits from the council or alternative third parties. As the non-negotiable aspect of BNG requirements, the cost may impact on the viability of the sites and its ability to deliver against other policy requirements such as affordable housing, developers would need all information to be able to make an informed decision on possible options.

No

ID sylw: 106437

Derbyniwyd: 05/03/2025

Ymatebydd: Porterbrook Mid Leasing Company

Asiant : Planning Prospects

The draft policy direction requires all development proposals to achieve a minimum of 10% BNG (or any higher percentage mandated through local or national policy / legislation) unless a development is exempt. This duplicates the general biodiversity gain condition requirement (as set out in schedule 7a of the town and country planning act 1990 (as amended). In England it is mandatory (under schedule 7a of the town and country planning act 1990 (as inserted by schedule 14 of the environment act 2021) that developers must deliver a BNG of 10% unless the development meets one of the listed exemption criteria. This means that development (that is not exempt) will result in more of better-quality natural habitat than there was before the development. However, the draft SWLP policy direction 38 goes on to say that as work on the local plan progresses, the councils will explore evidence to seek a higher percentage of BNG above the statutory 10% requirement to achieve greater biodiversity benefits. The current requirement for a minimum of 10% BNG is already a significant barrier for some development proposals to achieve, and in some cases makes development unfeasible and unviable. With this in mind it would not be justified or effective for policy to require a higher percentage of BNG where the existing policy (and legislation) already enables a higher percentage where possible. In conclusion, Porterbrook considers that it is unnecessary for policy to require a higher % provision over and above the statutory requirement because the statutory requirement, and indeed the draft policy direction, already includes a minimum 10% net gain requirement and therefore allows a higher percentage of net gain in habitat provision where possible.

No

ID sylw: 106478

Derbyniwyd: 28/02/2025

Ymatebydd: McCarthy Stone and Churchill Living

Asiant : The Planning Bureau Ltd

The Council should ensure that the proposed policy wording is consistent with relevant government guidance and Regulations. Although we recognise that the 10% is a minimum it should be for the developer to decide whether to go beyond this figure not the Council. It is important to remember that that it is impossible to know what the cost of delivering net gain is until the base level of biodiversity on a site is known and consequently what is required to
achieve a 10% net gain. On some sites this may be achievable on site with no reduction in developable area, for others it may require a large proportion of it to be addressed offsite or a significant reduction in the developable area – a far more expensive option that could
render a site unviable without a reduction in other policy requirements. The council should therefore not require BNG of greater than the 10%.

Yes

ID sylw: 106515

Derbyniwyd: 06/03/2025

Ymatebydd: Wychbury Developments

Asiant : Cerda Planning Ltd

We support the provisions of Policy Direction 38. 10% BNG is a requirement which properly should be set
out in policy.
Policy should go further, and make clear that any voluntary commitment to delivering BNG beyond 10% is a
significant benefit which should be put in to a planning balance assessment at development management
stage.

Yes

ID sylw: 106664

Derbyniwyd: 07/03/2025

Ymatebydd: Warwickshire Property and Development Group

Asiant : Framptons

While the policy direction aligns with national planning policy, before deciding on the appropriateness of imposing a BNG requirement above the statutory 10% we requested that Council explore, and evidence, how this might impact on:
• the development capacity of sites when balancing other technical and environmental considerations (i.e. making best use of land, maximising densities and delivering sustainable development); and
• the viability of development proposals when the BNG requirement is considered cumulatively alongside other policy requirements (e.g. net zero carbon) and likely
planning obligations.
Draft Policy Direction 38 has the potential to add additional development costs that must be factored into the Viability Assessment produced with the Pre-Submission SWLP.

No

ID sylw: 106811

Derbyniwyd: 07/03/2025

Ymatebydd: Bloor Homes

Asiant : Stantec

At present, the SWLP does not adequately address these issues, leading to a lack of justification for any requirement of biodiversity net gain that exceeds 10%.
As a result, Bloor Homes does not support the principle of this policy and emphasises that further justification is required for the implementation of this draft policy prior to the formal adoption of the SWLP.

No

ID sylw: 106980

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Homes

Asiant : Savills

We object to the consideration in draft Policy Direction 38 to seek a higher percentage of biodiversity net gain (‘BNG’) than the mandatory 10%. If a higher percentage is sought, then the policy should be supported by evidence base to ensure that the policy is justified in line with NPPF paragraph 36. Consideration should also be given to the implications that a higher BNG would have on the viability of sites and their ability to be delivered efficiently. The provision of on-site BNG above 10% will have implications on site yields and is likely to lead to more sites requiring allocation to meet the significant development needs of South Warwickshire.

No

ID sylw: 107171

Derbyniwyd: 07/03/2025

Ymatebydd: Sharba Homes

Asiant : Stantec

The SWLP does not adequately address these issues, leading to a lack of justification for any requirement of biodiversity net gain that exceeds 10%.
As a result, Sharba Homes does not support the principle of this policy and emphasises that further justification is required for the implementation of this draft policy prior to the formal adoption of the SWLP.

Other

ID sylw: 107179

Derbyniwyd: 05/03/2025

Ymatebydd: Sandwell Metropolitan Borough Council

“Under the mandatory system, developments (with some exceptions) are required to deliver 10% BNG. This will be achieved by delivering habitat on-site or, if that is not possible, through buying off-site biodiversity units.”

Developers may have access to their own BNG units and may not have to buy them.

“The purchase of registered offsite biodiversity units using the Local Nature Recovery Strategy as a guide and in line with the below locational hierarchy:
- Within the Local Planning Authority area where the impact occurs
- Within a neighbouring Local Planning Authority area
- Within Warwickshire, Coventry and Solihull
- Elsewhere in England”

The policy might also include reference to the provision of BNG units within the wider West Midlands before extending to the rest of the country.

Other

ID sylw: 107219

Derbyniwyd: 06/03/2025

Ymatebydd: Catesby Estates

Asiant : Mr Will Whitelock

The draft policy direction goes on to state that a higher percentage of BNG above the statutory 10% requirement is being explored.
Such an approach may unnecessarily burden development sites as the provision of net gains in biodiversity can impact on the viability of proposals and the capacity of sites. It is hence requested that the South Warwickshire authorities explore evidence on how a higher BNG would affect the capacity of sites when balancing other technical and environmental considerations and planning obligations.
Land south of Allimore Lane, Alcester will seek to deliver a minimum 10% in biodiversity net gain, alongside other on-site habitat provision and enhancement, through the retention of woodland habitats, enhancement of the setting of Spittle Brook, strengthening of hedgerow along the site frontages, and the creation of wildflower meadows around SuDS features which are tolerant to wetter conditions. Low-lying areas of the site would allow for the creation of wetland habitats to enhance the setting of the development and to provide net gains in biodiversity. In addition, the large arable field to the south of the Site provides a wide range of opportunities for good quality habitat creation.

Other

ID sylw: 107278

Derbyniwyd: 07/03/2025

Ymatebydd: Cotswolds National Landscape Board

In principle, the Cotswolds National Landscape (CNL) Board agrees with the approach laid out in Draft Policy Direction 38.
We are pleased to see that the Councils intend to explore evidence to seek a higher percentage of biodiversity net gain (BNG) above the statutory 10% requirements to achieve greater biodiversity benefits. As stated in Policy CE8 (Nature recovery and biodiversity) of the CNL Management Plan, development proposals within the CNL should provide at least 20% BNG, particularly with regards to the species and habitats listed in Appendix 8 of the Management Plan.75 Reasons why this higher level of BNG is justified in the BNG are provided in Appendix 9 of the Management Plan.76
We recommend that Draft Policy Direction 38 should require at least 20% BNG for development in the CNL.

Yes

ID sylw: 107365

Derbyniwyd: 06/03/2025

Ymatebydd: National Trust

Biodiversity Net Gain – As set out above, the National Trust are highly conscious of the poor conditions much of South Warwickshire’s natural environment are experiencing. We are supportive of the policy direction for BNG, with 10% required to be delivered as part of new development.

No

ID sylw: 107388

Derbyniwyd: 07/03/2025

Ymatebydd: Warwickshire Wildlife Trust

No. Warwickshire Wildlife Trust is 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 targetshould be delivered. A number of other Councils have already got plans through Examination with 20%.
If the Councils are serious about meeting the Governments 30 by 2030 targets in the Environment Act and Climate and Biodiversity Emergencies the plan needs to be ambitious.

Yes

ID sylw: 107466

Derbyniwyd: 05/03/2025

Ymatebydd: Temple Grafton Parish Council

Fully support