Q-C9.1: Please select the option which is most appropriate for South Warwickshire
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Biodiversity must be on exactly the same site that is being developed rather than several miles away where the actual residents or affected creatures would not benefit in the slightest. Do not green wash biodiversity
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Climate responsive development is obviously needed to safeguard our housing stock for future but more importantly efforts to reduce climate change are more important. We should not just focus on adapting.
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Council policy should promote green roofs/walls, which also provide cooling and pollution absorbing services. The Councils should make sure features are protected, so that once properties are bought and occupied, their new owners are limited as to what they can do. E.g. if developers are required to make less than 50% of the wider site concrete, owners must be prevented from concreting over their gardens, where bat boxes are put in, they must be protected, etc. Whether this is possible in the current planning system, we do not know. Employment of a Council ecologist/ecologists to look over such projects and provide independent assessment, rather than relying on promises provided by developers on the basis of their ecologists', which may be dubious or impossible for the Council to check.
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This is just wishful thinking practical solutions are what is needed. The countryside is where nature abounds a small change in agricultural land use makes the development issue insignificant.
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- Q-C7: We support option C7c. We do not think the Local Plan is the right place for such policies which are being set at a national level already. - Q-C8: We support option C8c. We do not think the Local Plan is the right place for such policies which are being set at a national level already. - Q-C9.1: We support option C9.1c. We do not think the Local Plan is the right place for such policies which are being set at a national level already.
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One of the most effective ways of promoting biodiversity and mitigating loss is to value and protect those areas which already support biodiversity. One such area is the Green Belt, in particular Green Belt land with low levels of human access such as farmland and wildlife refuges/corridors. It is therefore of great concern that all five spatial growth options propose Green Belt development and that the first three options propose to put a majority of development on Green Belt land.
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Policy option C9 looks to introduce an ‘Mitigating Biodiversity Loss’ policy. This appears to be looking at ‘Biodiversity Net Gain’ (BNG)requirements and the policy area should use this term to avoid confusion. The Council should make sure it does not set a higher Biodiversity Net Gain (BNG) requirement for development than that set out in the Environment Act 2021. Requiring BNG above 10% does not meet the tests set out in paragraph 57 of the NPPF and in particular a greater than 10% requirement is not necessary to make development acceptable in planning terms. A 10% requirement should therefore be maintained in order to ensure that the requirement is ‘fairly and reasonably related in scale and kind to the development’ (para 57, NPPF). 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 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 off-site 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 a BNG of greater than the 10%.
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- We support option C9.1c. Any requirements should be set at the national level unless there are very specific reasons and a sound reasoning for needing a different requirement to meet local circumstances.
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No comment
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Stop building any more houses.
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This should be done in consulatation with appropriate NGO's such as Warwickshire Wildlife Trust, the RSPB etc. It must not simply be a greenwash.
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3.44 Option C9.1a is the most appropriate option for South Warwickshire and is in accordance with paragraphs 177d and 182b of the NPPF which seek to secure biodiversity net gain via plan-making. 3.45 However, any planning policy requiring new development to incorporate measures to increase biodiversity should be flexible and adhere to the PPG [Paragraph 022 Reference ID: 8-022-20190721] which states, “biodiversity net gain can be achieved onsite, off-site or through a combination of on-site and off-site measures”. 3.46 It is recommended WDC and SOADC work with Warwickshire County Council (WCC) to identify ‘habitat banks’ i.e. areas of enhanced or created habitats which generate biodiversity credits. This will support strategic sites that are unable to deliver net gain wholly on site.