Warwickshire Wildlife Trust is broadly supportive of policy NE3 but believes that the current wording is not entirely compliant with the principles of the National Planning Policy Framework (NPPF).

Our principal concern is with the provisions of clause A, which requires development proposals to 'lead to no net loss of biodiversity, where appropriate'. This clause is inconsistent with paragraph 109 of the NPPF which requires the planning system to '[minimise] impacts on biodiversity and [provide] net gains in biodiversity where possible, contributing to the Government's commitment to halt the overall decline in biodiversity'.

The principle of net gain for biodiversity is now firmly established in Government policy, though the Natural Environment White paper and Biodiversity 2020 - a Strategy for England's Wildlife and Ecosystem Services. The Government recognises that to halt the loss of biodiversity, there needs to be a shift towards creating more, bigger, better and joined places for nature and by establishing coherent ecological networks. We believe that the policy's current wording, which will in effect maintain the status quo in terms of biodiversity, will not be ambitious enough to achieve these ends.

Furthermore, we recognise that it was previously difficultly to demonstrate net gain in planning applications without substantial habitat enhancements which are difficult to justify as part of the planning application. However, the recent introduction of a biodiversity impact calculator from the Biodiversity Offsetting pilot scheme has now provided an alternative way of calculating relative loss and gains of biodiversity on site. This means that there is now a simplified, transparent and effective way of demonstrating biodiversity gain for all planning applications, whatever the size or scale.

As a reference to this 'approved ecological assessment' is already included in the policy wording, we see no reason as to why the principles of Government Policy and the NPPF cannot be upheld and that a net gain for biodiversity be firmly upheld as a policy requirement in NE3.