Q-C9.1: Please select the option which is most appropriate for South Warwickshire
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Q-C9.1 – Please select a biodiversity option which is most appropriate for South Warwickshire In our view it is not necessary for the SWLP to include a policy requiring new developments to incorporate measures to increase biodiversity. In November of this year it will be a statutory requirement for all development proposals to demonstrate 10% biodiversity net gain. As this is set out in the Act it does not need to be repeated in policy.
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Q-C8: Please select the option which is most appropriate for South Warwickshire Option C8b: Do not include a policy that goes beyond existing building regulations, requiring new development and changes to existing buildings to incorporate measures to adapt to flood and drought events 2.69. The Respondent is generally supportive of the management and use of water within new developments and already seeks to incorporate SUDS in its schemes where it is feasible to do so. Furthermore, the Respondent has no in principle objection to the implementation of measures to reduce water consumption, however, they would not currently support a policy which goes beyond existing Building Regulations. Q-C9.1: Please select the option which is most appropriate for South Warwickshire Option C9.1b: Do not include a policy requiring new development and changes to existing buildings to incorporate measures to increase biodiversity 2.70. The Respondent is generally supportive of incorporating measures to increase biodiversity within new developments and notes that the need to provide 10% Biodiversity Net Gain (BNG) is soon to become mandatory under the Environment Act 2021. In light of which the need for an additional policy is unclear. 2.71. The introduction of any policy that has the potential to affect the viability and delivery of sites needs to be cautiously considered, with overly prescriptive requirements (such as limitations on the amount of hard landscaping that can be used within sites etc.) avoided. In the Respondent’s view, suggestions regarding how a development might go about achieving biodiversity increases on site should be set out in supporting text and not directly in policy wording to reflect best practice rather than a strict policy requirement. 2.72. While the delivery of on-site BNG may be preferred, the ability to deliver off-site BNG should not be ruled out, since there will be sites where BNG on site is not achievable. In this regard it is imperative that the SWLP provides an appropriate mechanism for offsetting when it is simply impractical to provide the level of net gain by any calculator being adopted by Natural England. 2.73. For the avoidance of doubt, the Respondent would have significant objections if the level of BNG required in South Warwickshire were to extend beyond the 10% required in line with the provisions of the Environment Act 2021.
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Land-use planning must have policies to create new tree planting at the scale necessary to meet net-zero carbon. The Government has committed to a vast tree-planting programme and it recognises that we need to make sure that the right trees are planted in the right places. Finding land to plant on this scale requires careful planning. Sufficient land suitable for tree planting should be identified through the plan process.
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Q-C9.1: Biodiversity Net Gain has been introduced into national guidance; it aims to leave the natural environment in a measurably better state than it was to start with. It should be reflected in Local Plan Part 1.
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Q-C9.1 - Please select the option which is most appropriate for South Warwickshire: 1) Option C9.1a: Include a policy requiring new development and changes to existing buildings to incorporate measures to increase biodiversity. 2) Option C9.1b: Do not include a policy requiring new development and changes to existing buildings to incorporate measures to increase biodiversity. We do not object in principle to the inclusion of a policy requiring a net gain in biodiversity provided that the policy wording allows for flexibility and allows for off-site mitigation where a net gain cannot be met in full on-site. This requirement will soon gain Royal Assent through the Environment Bill; therefore, it is prudent to include a policy on biodiversity net gain. It seems onerous to include in policy a requirement that less than 50% of a wider site is to consist of paved / hard surfaces. It could be an aim or ambition but needs to allow for site flexibility (e.g. a site might require 52% hard surfaces but still be more than acceptable in drainage terms.
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Biodiversity Net Gain has been introduced into national guidance; it aims to leave the natural environment in a measurably better state than it was to start with. It should be reflected in Local Plan Part 1.
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Issue – C9.1a: Support. Biodiversity is a strategic issue that does not recognise administrative boundaries, RBC understands the advantages of taking a joint approach to joint working to deliver biodiversity enhancements that will ultimately benefit us all.
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Issue C6: Whole Life-Cycle carbon emissions assessments Q-C6.1c – none of these. The requirement for such an assessment would be unduly onerous on the developers and we would argue that Building Regulations and the need to comply with them, will adequately safeguard emissions to agreed levels (set nationally by the Government). Issue C7: Adapting to higher Temperatures C7b: We do not believe that a policy requiring new developments to incorporate measures to adapt to higher temperatures are necessary, particularly within Part 1 of the Plan. We consider that such measures are most likely to occur through the market in time, if required. If it were to become part of a policy requirement, we would expect that viability would be taken into account. Such measures should be carefully considered to ensure that they do not stifle the provision of much needed dwellings across the District. Issue C8: Adapting to flood and drought events Option C8b: We consider that there is no requirement to have a specific policy to incorporate measures to adapt to flood and drought events. This would be a duplication of Building Regulations which are being updated regularly to manage flood risk and water consumption. The frequency of changes to Building Regulations will probably mean that plans adopted to align with current standards will soon be out of date. Issue C9: Mitigating Biodiversity Loss Q-C91a. The Environment Act 2021 requires all planning permissions in England to deliver at least 10% biodiversity net gain (date yet to be confirmed but expected to be November 2023). The NPPF already encourages BNG and most developers accept that their proposals will need to take account of it. Most new local plans are including specific policies dealing with biodiversity loss and gain. Any policy should be consistent with national policy and subject to thorough evidence testing and consulted upon as the Plan progresses.
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NPPF Paragraph 32 advises that local plans should address relevant environmental objectives, including opportunities for net gains. Where significant adverse impacts are unavoidable, suitable mitigation measures should be proposed (or, where this is not possible, compensatory measures should be considered). Further, Paragraph 174 advises that planning policies and decisions should contribute to and enhance the natural and local environment by minimising impacts on and providing net gains for biodiversity, including establishing coherent ecological network that are more resilient to current and future pressures. L&Q Estates are supportive of Option C9.1a: Include a policy requiring new development and changes to existing buildings to incorporate measures to increase biodiversity. The Site will seek to deliver a minimum 10% in biodiversity net gain, alongside other on-site habitat provision and enhancement, through the retention of existing hedgerows, the retention and enhancement of the off-site brook located adjacent to the south eastern corner of the site, and the creation of new habitats including wildflower grassland areas, native woody tree planting, wetland areas, ponds and Sustainable Drainage Systems (SuDS). It should be noted that the large arable field to the south of the Site (approximately 50% of the total site area) is proposed to be retained in agricultural use. It is proposed to provide a large landscape buffer between the field to the south and built development in the northern half of the site. This will provide significant opportunities for good quality habitat creation and to achieve a net gain in biodiversity.
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No answer given
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52. NPPF Paragraph 32 advises that local plans should address relevant environmental objectives, including opportunities for net gains. Where significant adverse impacts are unavoidable, suitable mitigation measures should be proposed (or, where this is not possible, compensatory measures should be considered). Further, Paragraph 174 advises that planning policies and decisions should contribute to and enhance the natural and local environment by minimising impacts on and providing net gains for biodiversity, including establishing coherent ecological network that are more resilient to current and future pressures. 53. The site will seek to deliver a biodiversity net gain, alongside other on-site habitat provision and enhancement, the site provides a wide range of opportunities for good quality habitat creation., however this should not be higher that the incoming 10% target.
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50. NPPF Paragraph 32 advises that local plans should address relevant environmental objectives, including opportunities for net gains. Where significant adverse impacts are unavoidable, suitable mitigation measures should be proposed (or, where this is not possible, compensatory measures should be considered). Further, Paragraph 174 advises that planning policies and decisions should contribute to and enhance the natural and local environment by minimising impacts on and providing net gains for biodiversity, including establishing coherent ecological network that are more resilient to current and future pressures. Spitfire are supportive on encouraging biodiversity net gain of development but this should be require a higher target than 10% in biodiversity net gain
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Q-C9.1: Please select the option which is most appropriate for South Warwickshire 5.4. Persimmon are supportive of the need to address net losses to biodiversity through the provision of enhancement to deliver an overall net gain. The Environment Act will require all development to provide at least a 10% Biodiversity Net Gain (BNG) increase and there would be no objection to this being carried through into a local policy. Indeed, it would reflect one of the core principles of the NPPF to conserve and enhance the natural environment. 5.5. Any such policy though, should be drafted to provide as much flexibility as possible. The test is whether the 10% BNG is delivered, not the method by which it is delivered. It is important that the way in which ‘net gains’ are calculated is given careful consideration and a pragmatic view should be taken in terms the delivery of biodiversity enhancements where there are clear landscape and habitat improvements, rather than being wholly reliant on the output of a rigid calculator, in particular where this could impede viability and thus the delivery of much needed housing. It should also allow for contributions to be made towards off-site mitigation with suitable receptor sites or projects identified through the Local Plan process to secure the deliverability of development.
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ISSUE C9: MITIGATING BIODIVERSITY LOSS Q-C9.1: Please select the option which is most appropriate for South Warwickshire 2.45 NPPF Paragraph 32 advises that local plans should address relevant environmental objectives, including opportunities for net gains. Where significant adverse impacts are unavoidable, suitable mitigation measures should be proposed (or, where this is not possible, compensatory measures should be considered). Further, Paragraph 174 advises that planning policies and decisions should contribute to and enhance the natural and local environment by minimising impacts on and providing net gains for biodiversity, including establishing coherent ecological network that are more resilient to current and future pressures. 2.46 Ellis Machinery is supportive of the requirement to enhance biodiversity across development sites. The provisions of the Environment Act 2021 requiring a 10% net gain secured through a planning condition will come into force in November 2023. Planning Policy should reflect this change to the planning context. Option C9.1a is considered to be the most appropriate for South Warwickshire.
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Q-C9.1: Please select the option which is most appropriate for South Warwickshire 5.4. Persimmon are supportive of the need to address net losses to biodiversity through the provision of enhancement to deliver an overall net gain. The Environment Act will require all development to provide at least a 10% Biodiversity Net Gain (BNG) increase and there would be no objection to this being carried through into a local policy. Indeed, it would reflect one of the core principles of the NPPF to conserve and enhance the natural environment. 5.5. Any such policy though, should be drafted to provide as much flexibility as possible. The test is whether the 10% BNG is delivered, not the method by which it is delivered. It is important that the way in which ‘net gains’ are calculated is given careful consideration and a pragmatic view should be taken in terms the delivery of biodiversity enhancements where there are clear landscape and habitat improvements, rather than being wholly reliant on the output of a rigid calculator, in particular where this could impede viability and thus the delivery of much needed housing. It should also allow for contributions to be made towards off-site mitigation with suitable receptor sites or projects identified through the Local Plan process to secure the deliverability of development.
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It is not necessary for a SWLP to include a policy requiring new developments to incorporate measures to increase biodiversity. In November of this year it will be a statutory requirement for all development proposals to demonstrate 10% biodiversity net gain. As this is set out in the Act it does not need to be repeated in policy.
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Developments should be required to make a measurable contribution to increasing biodiversity in the immediate area.
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2.21 Biodiversity net-gain (C9.1) 2.21.1 Providing biodiversity net gains is consistent with paragraph 174 of the NPPF and the Environment Act 2021. It is suggested that the policy under 9.1a is couched in these terms rather than having an arbitrary maximum percentage of paved/hard surfaces on site – which may not achieve the intended objective of a net gain in biodiversity.
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Q-C8 47. Standards concerning flooding and sustainable drainage for new homes should accord with national policy and regulations rather than specific standards seeking to be imposed by this Local Plan with the attendant higher costs which would inevitably be incurred and affecting the affordability of the dwelling. Q-C9.1 48. Richborough Estates is supportive of new development including appropriate green and blue infrastructure which provides for sustainable drainage and biodiversity opportunities, alongside creating a scheme where people want to live. However, any biodiversity standards for housing schemes should accord with national policy rather than specific standards seeking to be imposed by this Local Plan with the attendant higher costs which would inevitably be incurred and affecting the affordability of the dwelling.
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Q-C9.1: Please select the option which is most appropriate for South Warwickshire Option C9.1a: Include a policy requiring new development and changes to existing buildings to incorporate measures to increase biodiversity Option C9.1b: D0 not include a policy requiring new development and changes to existing buildings to incorporate measures to increase biodiversity Option C9.1c: None of these 5.4. Catesby Estates are supportive of the need to address net losses to biodiversity through the provision of enhancement to deliver an overall net gain. The Environment Act will require all development to provide at least a 10% Biodiversity Net Gain (BNG) increase and there would be no objection to this being carried through into a local policy. Indeed, it would reflect one of the core principles of the NPPF to conserve and enhance the natural environment. 5.5. Any such policy though, should be drafted to provide as much flexibility as possible. The test is whether the 10% BNG is delivered, not the method by which it is delivered. It is important that the way in which ‘net gains’ are calculated is given careful consideration and a pragmatic view should be taken in terms the delivery of biodiversity enhancements where there are clear landscape and habitat improvements, rather than being wholly reliant on the output of a rigid calculator, in particular where this could impede viability and thus the delivery of much needed housing.
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Q-C8 49. Standards concerning flooding and sustainable drainage for new homes should accord with national policy and regulations rather than specific standards seeking to be imposed by this Local Plan with the attendant higher costs which would inevitably be incurred and affecting the affordability of the dwelling. Q-C9.1 50. Richborough Estates is supportive of new development including appropriate green and blue infrastructure which provides for sustainable drainage and biodiversity opportunities, alongside creating a scheme where people want to live. However, any biodiversity standards for housing schemes should accord with national policy rather than specific standards seeking to be imposed by this Local Plan with the attendant higher costs which would inevitably be incurred and affecting the affordability of the dwelling.
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Q-C8 49. Standards concerning flooding and sustainable drainage for new homes should accord with national policy and regulations rather than specific standards seeking to be imposed by this Local Plan with the attendant higher costs which would inevitably be incurred and affecting the affordability of the dwelling. Q-C9.1 50. Richborough Estates is supportive of new development including appropriate green and blue infrastructure which provides for sustainable drainage and biodiversity opportunities, alongside creating a scheme where people want to live. However, any biodiversity standards for housing schemes should accord with national policy rather than specific standards seeking to be imposed by this Local Plan with the attendant higher costs which would inevitably be incurred and affecting the affordability of the dwelling
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Q-C8 46. Standards concerning flooding and sustainable drainage for new homes should accord with national policy and regulations rather than specific standards seeking to be imposed by this Local Plan with the attendant higher costs which would inevitably be incurred and affecting the affordability of the dwelling. Q-C9.1 47. Richborough Estates is supportive of new development including appropriate green and blue infrastructure which provides for sustainable drainage and biodiversity opportunities, alongside creating a scheme where people want to live. However, any biodiversity standards for housing schemes should accord with national policy rather than specific standards seeking to be imposed by this Local Plan with the attendant higher costs which would inevitably be incurred and affecting the affordability of the dwelling.
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Q-C8 47. Standards concerning flooding and sustainable drainage for new homes should accord with national policy and regulations rather than specific standards seeking to be imposed by this Local Plan with the attendant higher costs which would inevitably be incurred and affecting the affordability of the dwelling. Q-C9.1 48. Richborough Estates is supportive of new development including appropriate green and blue infrastructure which provides for sustainable drainage and biodiversity opportunities, alongside creating a scheme where people want to live. However, any biodiversity standards for housing schemes should accord with national policy rather than specific standards seeking to be imposed by this Local Plan with the attendant higher costs which would inevitably be incurred and affecting the affordability of the dwelling.
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MAOL supports the principal of biodiversity net gain and is keen to ensure that any policy can be implemented on a site by site basis. It should not, therefore, include site specific requirements e.g. larger developments to have less than 50% of the wider site consisting of hard surfaces.
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Include a policy that requires new developments and changes to existing buildings to incorporate measures to adapt to higher temperatures. 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. Q W.1 - In August last year, the United Nations General Assembly declared that everyone on the planet has a right to a healthy environment, including clean air, water and a stable climate. The Clean Air (Human Rights) Bill is being considered by the UK government to ensure the government takes action to bring air quality in every community up to World Health Organisation minimum standards PM 2.5 Air Pollutants on Henley High street already exceed WHO guidelines. Further development will increase congestion and pollution. Uptake of electric vehicles is slow so it is questionable that this will significantly mitigate this in our lifetimes. So yes, pollution should absolutely be taken into account.
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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.