No

ID sylw: 107924

Derbyniwyd: 07/03/2025

Ymatebydd: Catesby Estates Ltd

Asiant : Stantec

Draft Policy Direction 39 states:
“We will aim to have a policy that requires development to contribute positively to the natural environment by providing measurable net improvements in biodiversity and ecosystem services. The initial focus will be on BNG and carbon sequestration, but the policy will be updated to incorporate other ecosystem services as a comprehensive ENG framework is developed.”
The supporting text to this policy confirms that the intention is that this policy look at all ecosystem services, beyond just biodiversity, including air quality, water quality, climate resilience and carbon sequestration, and will look to address these in tandem to ensure an overall net gain in ecosystem services.
Whilst this approach is commendable, it is difficult to foresee how such a policy will be formulated to deliver measurable outcomes. The evidence base for the SWLP must also include a thorough assessment of the viability of this policy to ensure that it does not unduly stifle
development.

No

ID sylw: 107981

Derbyniwyd: 07/03/2025

Ymatebydd: Rainier Developments 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.

No

ID sylw: 108092

Derbyniwyd: 07/03/2025

Ymatebydd: Seven Homes

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 considered to be unjustified

Other

ID sylw: 108199

Derbyniwyd: 27/02/2025

Ymatebydd: St Philips

Asiant : Lichfields (Birmingham)

Do you agree with the approach laid out in Draft Policy Direction –39- Environmental Net Gain? 2.105 The purpose of the planning system is to contribute to the achievement of sustainable development (Para 7, NPPF), and the NPPF is clear that sustainable development comprises three overarching objectives: economic, social and environmental (Para 8). It is also clear that opportunities should be taken to achieve net gains (Para 8). On the face of it, the delivery of Environmental Net Gain [ENG] would align with the NPPF and also be appropriate given that the SWAs have declared climate emergencies – it would also align with WDC’s ‘Climate Emergency Action Programme’ and SOADC’s ‘Council Plan 2019- 2023’. Therefore, in principle, St Philips broadly supports the SWA’s wider sustainable development aspirations and the principle of ENG. 2.106 St Philips understands that ENG comprises a series of holistic ‘net improvements’ to nature, such as water quality and air quality (etc.). In this regard, and notwithstanding St Philips’ broad support, the SWAs should again have regard to paragraph 16(f) of the NPPF (i.e. serve a clear purpose and avoid ‘unnecessary duplication). Crucially, Development Plans should be read as a whole. To this end, in its current form, St Philips considers that the draft policy would not ‘serve a clear purpose’, nor avoid ‘unnecessary duplication’ as the decision taker would need to have regard to the wider SWLP policies – such as (inter alia) draft Policy Directions 22, 24, 29, and 39 – when reading the SWLP as a whole. 2.107 Moreover, the NPPF is clear that policies should be aspirational, but deliverable (Para 16b), and be clearly written and unambiguous, so it is evident how a decision-maker should react to development proposals (Para 16d). Whilst it is recognised that the SWAs are at the early stages of plan-making, at present, St Philips is concerned that the SWAs may seek to make provision for a policy that is ‘aspirational’, but not ‘deliverable’ as – at present – the policy is ‘unclear’ as no ENG framework presently exists. Indeed, the SWAs recognise this in the PO (Pg.158), stating that one has not been formulated.

No

ID sylw: 108235

Derbyniwyd: 07/03/2025

Ymatebydd: Persimmon Homes (South Midlands)

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 considered to be unjustified.

No

ID sylw: 108345

Derbyniwyd: 07/03/2025

Ymatebydd: Caddick Land

Asiant : Stantec

The supporting text to this policy confirms that the intention is that this policy look at all ecosystem services, beyond just biodiversity, including air quality, water quality, climate resilience and carbon sequestration, and will look to address these in tandem to ensure an overall net gain in ecosystem services.

Whilst this approach is commendable, it is difficult to foresee how such a policy will be formulated to deliver measurable outcomes. The evidence base for the SWLP must also include a thorough assessment of the viability of this policy to ensure that it does not unduly stifle
development.

Other

ID sylw: 108376

Derbyniwyd: 07/03/2025

Ymatebydd: Mackenzie Miller Homes

Asiant : Lichfields (Birmingham)

15.1 Paragraph 7 of the NPPF states that the purpose of the planning system is to contribute to
the achievement of sustainable development and Paragraph 8 of the NPPF is clear that
sustainable development comprises three overarching objectives: economic, social and
environmental. It is also clear that opportunities should be taken to achieve net gains (Para
8). On the face of it, the delivery of Environmental Net Gain [ENG] would align with the
NPPF and also be appropriate given that the SWCs have declared climate emergencies – it
would also align with WDC’s ‘Climate Emergency Action Programme’ and SOADC’s
‘Council Plan 2019-2023’. As such, Mackenzie Miller Homes broadly supports the SWC’s
wider sustainable development aspirations and the principle of ENG.
15.2 Mackenzie Miller Homes recognises that ENG involves a series of comprehensive 'net
improvements' to nature, including enhancements to water and air quality. Despite
Mackenzie Miller Homes overall support, the SWCs should consider Paragraph 16(f) of the
NPPF, which emphasizes serving a clear purpose and avoiding unnecessary duplication. It's
crucial to read Development Plans in their entirety. Therefore, Mackenzie Miller Homes
believes that, in its current form, the draft policy does not 'serve a clear purpose' or avoid
'unnecessary duplication,' as decision-makers must consider the broader SWLP policies,
such as draft Policy Directions 22, 24, 29, and 39, when interpreting the SWLP as a whole
15.3 Furthermore, Paragraph 16(b) of the NPPF is clear that policies should be aspirational, but
deliverable and Paragraph 16(d) sets out that policies should be clearly written and
unambiguous, so it is evident how a decision-maker should react to development proposals.
15.4 While it is acknowledged that the SWCs are in the early stages of plan-making, Mackenzie
Miller Homes is currently concerned that the SWCs may aim to establish a policy that is
'aspirational' but not 'deliverable.' At present, the policy is 'unclear' due to the absence of an
existing ENG framework. The SWCs themselves acknowledge this in the PO (Pg.158),
noting that such a framework has not yet been formulated.

No

ID sylw: 108469

Derbyniwyd: 06/03/2025

Ymatebydd: The Bird Group

Asiant : Framptons

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: 108528

Derbyniwyd: 07/03/2025

Ymatebydd: Bevan Family

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: 108556

Derbyniwyd: 29/06/2025

Ymatebydd: Hayfield Homes

It is considered that provisions relating to Environmental Net Gain would cause unnecessary confusion in the context of the mandatory BNG requirements. It is considered that such a policy would not be justified, and Policy Direction 39 should be deleted.

No

ID sylw: 108594

Derbyniwyd: 07/03/2025

Ymatebydd: Corbally Group (Harbury) 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 considered to be unjustified.

Other

ID sylw: 108641

Derbyniwyd: 07/03/2025

Ymatebydd: Kiely Bros Holdings Ltd

Asiant : Pegasus Group

Policy Direction 39 – Environmental Net Gain
10.6.
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 considered to be unjustified.