Other

ID sylw: 103699

Derbyniwyd: 07/03/2025

Ymatebydd: Richborough - Wellesbourne Road, Wellesbourne

Asiant : Turley

Richborough note that this is an emerging area of policy and highlight the justification text at page 158 of the Preferred Options Plan, which states: “Further evidence is required to demonstrate the need for Environmental Net Gain and to help formulate specific policies for the Local Plan”. Until this further information is available to demonstrate there is a need for Environmental Net Gain Strategy, stakeholders are unable to provide a robust response.

Other

ID sylw: 103700

Derbyniwyd: 07/03/2025

Ymatebydd: Richborough - Plough Lane, Bishop's Itchington

Asiant : Turley

Richborough note that this is an emerging area of policy and highlight the justification text at page 158 of the Preferred Options Plan, which states: “Further evidence is required to demonstrate the need for Environmental Net Gain and to help formulate specific policies for the Local Plan”. Until this further information is available to demonstrate there is a need for Environmental Net Gain Strategy, stakeholders are unable to provide a robust response.

Other

ID sylw: 103843

Derbyniwyd: 07/03/2025

Ymatebydd: Claire Jones

This is not ambitious or developed enough!!

Yes

ID sylw: 104268

Derbyniwyd: 07/03/2025

Ymatebydd: Mr Stephen Norrie

This seems a reasonable approach, given present political economic orthodoxy.

Yes

ID sylw: 104461

Derbyniwyd: 07/03/2025

Ymatebydd: South Warwickshire Foundation trust

We agree and support this approach

Yes

ID sylw: 104674

Derbyniwyd: 07/03/2025

Ymatebydd: Mr Neal Appleton

_

Yes

ID sylw: 104822

Derbyniwyd: 07/03/2025

Ymatebydd: Mr Joe Rukin

This is a laudable aim, but in achieving it you must surely take into account initiatives being undertaken by HS2 Ltd, yet SG01 and SG02 overlap with these schemes.

Yes

ID sylw: 104842

Derbyniwyd: 07/03/2025

Ymatebydd: Miss Ann Colley

agree with strict controls over the developer

No

ID sylw: 104863

Derbyniwyd: 07/03/2025

Ymatebydd: Dr Susan Hood

Policy not strong enough and there is no commitment: "we will aim". Carbon sequestration should only be a focus where it promotes BNG/does not negatively impact BNG (or is linked to reducing emissions from power/heat generation). Encouragement to reduce carbon emissions via e.g. less traffic congestion, energy efficiency and renewables policies.

Yes

ID sylw: 105014

Derbyniwyd: 07/03/2025

Ymatebydd: Ms Susan Ingleby

Yes

Yes

ID sylw: 105017

Derbyniwyd: 07/03/2025

Ymatebydd: Fern Arnold

I agree with an integrated ENG alongside BNG so that the housing and land is future proofed and eco friendly. Insulation, electric car points, solar and or heat pumps etc. Not just housing but schools, hospitals, offices and industrial. Can solar panels be retrofitted on tops of buildings, car parks etc.

Yes

ID sylw: 105026

Derbyniwyd: 07/03/2025

Ymatebydd: H Crook

Absolutely essential to integrate to protect our environment for all species health and survival including our own.
Also No building on flood plains to prevent downstream flooding
Climate change, Building and development on green sites, air pollution and water pollution make the essential for our native species survival, as well as our own.

Other

ID sylw: 105117

Derbyniwyd: 27/02/2025

Ymatebydd: St Philips

Asiant : Lichfields (Birmingham)

St Philips understand that the planning system aims to support sustainable development, which includes economic, social, and environmental objectives, and support the concept of Environmental Net Gain (ENG). However, St Philips believe that the draft policy lacks a clear purpose and may result in unnecessary duplication when considered alongside existing policies. Additionally, while St Philips acknowledge the SWAs are in the early stages of plan-making, St Philips are concerned that the policy may be aspirational but not deliverable due to the absence of a defined ENG framework.

No

ID sylw: 105305

Derbyniwyd: 28/02/2025

Ymatebydd: Warwickshire Wildlife Trust

No. It is unclear how this will deliver wider connecting corridors which are more substantial than the proposed small scale on-site improvements. The councils should update their Green/Blue Infrastructure evidence base, in line with the NPPF and in time to influence chosen housing sites in the Local Plan.

No

ID sylw: 105784

Derbyniwyd: 07/03/2025

Ymatebydd: Wates Developments Ltd

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.
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.

Other

ID sylw: 106215

Derbyniwyd: 07/03/2025

Ymatebydd: Cala Homes (Cotswolds)

Asiant : Lichfields (London)

Cala supports the general approach of Draft Policy Direction 39 but recognises that it will be important to develop this policy further, with further background evidence to justify the aspirations set out within any future detailed policy. A comprehensive framework that is able to fairly and accurately assess what Environmental Net Gain (ENG) should cover, and the level of ENG which developments would need to achieve, will be important. Whilst Cala recognises the potential benefits of ENG, given its broader scope to consider wider environmental issues beyond biodiversity net gain alone, (e.g. air quality, water quality and climate resilience) - Cala believes, as per its comments on BNG, that careful consideration should be given to potential
impact on viability to ensure that forthcoming developments are not hindered.

Other

ID sylw: 106375

Derbyniwyd: 07/03/2025

Ymatebydd: West Midlands Housing Association Planning Consortium

Asiant : Tetlow King Planning

It is currently unclear what a policy on Environmental Net Gain (ENG) would entail. If the Council wishes to pursue this as a policy in the next stage of consultation, justification for ENG is required alongside consideration of how such a policy may impact viability of developments and thus hinder the delivery of affordable housing in SW.

No

ID sylw: 106438

Derbyniwyd: 05/03/2025

Ymatebydd: Porterbrook Mid Leasing Company

Asiant : Planning Prospects

The draft policy direction sets out that Environmental Net Gain (ENG) is an approach to development that leaves the environment in a measurably better state than prior to development. It looks holistically across all ecosystem services, beyond just biodiversity, including air quality, water quality, climate resilience, etc. And addresses these in tandem to ensure an overall net gain in ecosystem services. It sets out that the broader scope, compared to Biodiversity Net Gain (BNG) alone, provides additional benefits for both the environment and people. The policy will require development proposals to contribute positively to the natural environment by enhancing biodiversity and ecosystem services. The direction says that further work is required to develop a comprehensive ENG framework, but an initial focus on BNG and carbon sequestration will provide a solid foundation. Additionally, Porterbrook’s response to draft policy 38 (BNG) highlights that 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 the swlp to require a further policy requirement in the form of an ENG percentage. In conclusion, whilst further work is noted before a comprehensive ENG framework can be confirmed and developed, the draft policy direction, in seeking to deliver measurable improvements in biodiversity and ecosystem services (including carbon sequestration) is duplicating other policy requirements around BNG, air quality, water quality, climate resilience etc. And in doing so is adding another, and unnecessary, policy layer (or burden) which duplicates requirements that are already covered by other national and (draft) local policy, and legislation. As such it is not justified or effective

No

ID sylw: 106479

Derbyniwyd: 28/02/2025

Ymatebydd: McCarthy Stone and Churchill Living

Asiant : The Planning Bureau Ltd

The Council should not set a higher environmental target than those already set out by government, the Building Regulations and those set out in the Environment Act 2021. This includes ensuring that the Council does not require BNG above 10%. Any environmental
target beyond the current legislation would need to be fully evidenced and justified and ensure it meets the requirements of paragraph 58 of the NPPF and in particular ensure that any requirement is ‘fairly and reasonably related in scale and kind to the development’.

No

ID sylw: 106665

Derbyniwyd: 07/03/2025

Ymatebydd: Warwickshire Property and Development Group

Asiant : Framptons

Whilst we recognise that by incorporating natural capital into planning, local authorities can, in theory, make more informed decisions that balance development with environmental sustainability, we are concerned that this subject area needs to mature further before it forms a part of local planning policy.
Quantifying the value of natural assets and ecosystem services is widely recognised as being both complex and subjective, where different methodologies can yield varying results, making it difficult to establish a consistent valuation framework. Furthermore, accurate and comprehensive data on natural capital is often lacking, which can hinder the ability to make informed decisions and effectively integrate natural capital into planning. While also we believe that trying to simplify complex natural processes into models can lead to an oversimplification and misrepresentation of the true value and function of natural assets.
Instead of looking to introduce a policy requirement on Environmental Net Gain through the SWLP, the Councils should focus on successfully implementing other policies which seek to protect and enhance the natural and local environment, and for which a proven policy framework exists.

Other

ID sylw: 106812

Derbyniwyd: 07/03/2025

Ymatebydd: Bloor Homes

Asiant : Stantec

The explanatory text for this policy emphasises its goal of covering all ecosystem services, going beyond just biodiversity to also address factors like air quality, water quality, climate resilience, and carbon sequestration. The policy seeks to tackle these components in an integrated manner to achieve a holistic net gain in ecosystem services.
While this strategy is commendable, forecasting the policy's framework for generating measurable outcomes remains a complex task. Furthermore, the evidence base for the SWLP should include a thorough assessment of the policy's practicality to ensure it does not unduly impede development.

No

ID sylw: 106981

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Homes

Asiant : Savills

We object to Draft Policy Direction 39 as evidence has yet to be published to justify the inclusion of an Environmental Net Gain (ENG) policy, or how this works 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 to demonstrate how this can be delivered. As with our comments to Policy Direction 38, we also consider that the inclusion of an ENG policy could impact viability and site yields. It is also unclear how ENG will align with BNG and whether this is an additional requirement which will be placed on developers. Any requirement needs to be appropriately justified and evidenced (NPPF paragraph 36).

Other

ID sylw: 107172

Derbyniwyd: 07/03/2025

Ymatebydd: Sharba Homes

Asiant : Stantec

The explanatory text for this policy emphasises its goal of covering all ecosystem services, going beyond just biodiversity to also address factors like air quality, water quality, climate resilience, and carbon sequestration. The policy seeks to tackle these components in an integrated manner to achieve a holistic net gain in ecosystem services.
While this strategy is commendable, forecasting the policy's framework for generating measurable outcomes remains a complex task. Furthermore, the evidence base for the SWLP should include a thorough assessment of the policy's practicality to ensure it does not unduly impede development.

Other

ID sylw: 107180

Derbyniwyd: 05/03/2025

Ymatebydd: Sandwell Metropolitan Borough Council

It will be interesting to see how this policy is worded and delivered. At the moment, there is no detail of what it might cover apart from broad references to BNG, air / water quality, carbon sequestration and climate change. To cover several essentially different environmental issues in one policy could result in something extremely complex. It will also have implications for other policy areas. It is not clear how this policy area will support or direct following DPDs.

Other

ID sylw: 107279

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 39.
The principle of environmental net gain was embedded in Government policy in the Government’s ‘25 Year Plan to Improve the Environment’, published in 2018, in which it pledged that we would be the first generation to leave the environment in a better state than that in which we inherited it.77 This principle is maintained in the Government’s Environmental Improvement Plan (EIP) 2003, which is the Government’s first revision of the 25 Year Plan.78 The production of the EIP and annual reviews of the EIP is a legal requirement, under the Environment Act 2021.79
In the context of the CNL, a key component of delivering environmental net gain will be to meet the ambitious targets that are set out in the Protected Landscapes Targets and Outcomes Framework (PLTOF).80 The new CNL Management Plan 2025-2030, which was adopted by the Board in February 2025, sets out these targets and outcomes specifically in relation to the CNL.81
Achieving the PLTOF targets and outcomes is a key component of fulfilling the statutory duty to seek to further the purpose of conserving and enhancing the natural beauty of the CNL.82
We recommend that Draft Policy Direction 39 should set a requirement for development in the CNL to contribute to achieving the PLTOF targets and outcomes that are set out in the CNL Management Plan.
We also recommend that the supporting text should make reference to the EIP and to the PLTOF.

Yes

ID sylw: 107467

Derbyniwyd: 05/03/2025

Ymatebydd: Temple Grafton Parish Council

Fully support

Other

ID sylw: 107664

Derbyniwyd: 07/03/2025

Ymatebydd: Cala Homes (Cotswolds)

Asiant : Lichfields (London)

Draft Policy Direction 39 – Environmental Net Gain
Do you agree with the approach laid out in Draft Policy Direction 39 –Environmental Net Gain?
Cala supports the general approach of Draft Policy Direction 39 but recognises that it will be important to develop this policy further, with further background evidence to justify the aspirations set out within any future detailed policy. A comprehensive framework that is able to fairly and accurately assess what Environmental Net Gain (ENG) should cover, and the level of ENG which developments would need to achieve, will be important.
Whilst Cala recognises the potential benefits of ENG, given its broader scope to consider wider environmental issues beyond biodiversity net gain alone, (e.g. air quality, water quality and climate resilience) - Cala believes, as per its comments on BNG, that careful consideration should be given to potential impact on viability to ensure that forthcoming developments are not
hindered.

No

ID sylw: 107758

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Strategic Land

Asiant : Savills

We object to Draft Policy Direction 39 as evidence has yet to be published to justify the inclusion of an Environmental Net Gain (ENG) policy, or how this works 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 to demonstrate how this can be delivered. As with our comments to Policy Direction 38, we also consider that the inclusion of an ENG policy could impact viability and site yields. It is also unclear how ENG will align with BNG and whether this is an additional requirement which will be placed on developers. Any requirement needs to be appropriately justified and evidenced (NPPF paragraph 36).

No

ID sylw: 107858

Derbyniwyd: 05/03/2025

Ymatebydd: Catesby Estates Ltd

Asiant : Pegasus Group

This relates to securing a net gain in ecosystem services. At this stage, no framework for Environmental Net Gain (ENG) has been provided, and the concept is vague. Very limited detail is provided within the policy direction, which simply states that the focus of ENG will be BNG and carbon sequestration, both of which have their own standalone policy directions, and desired requirements for both do not need to be repeated here. This brings into question the necessity for an ENG policy, and substantial work is clearly needed to formulate a policy which is sound. Crucially, the evidence base does not currently demonstrate a need for this policy, as acknowledged by the Councils, thus it is unjustified.

Other

ID sylw: 107887

Derbyniwyd: 07/03/2025

Ymatebydd: Taylor Wimpey Strategic Land

Asiant : Turley

Careful consideration should be given to increasing the requirement for BNG above 10% and the implication this will likely have for delivery and viability.
Policy 38 should also recognise that landowners and developers may have access to additional land within the LPA or elsewhere, where they can provide for any additional offsite mitigation required. Offsite mitigation should not be limited to those sites identified through the LNRS.
Taylor Wimpey welcome the opportunity to comment further on any environmental net gain policy. Again, consideration should be given to how any additional requirements would impact site deliverability/viability, and sufficient evidence provided to demonstrate and justify the need to go above and beyond national standards.