Policy NE6: Designated biodiversity and geological sites

This is a minor objection to an otherwise endorsed policy and supporting text. Much of this policy and the supporting information is welcomed but greater clarity is required to explain what will be required to deliver no net loss and where possible net gain on non designated sites (as required by NPPF). Most of our biodiversity is contained on non designated sites which make up the majority of the district. NPPF seeks to conserve and enhance 'biodiversity' - not just that which occurs on designated sites, or only 'important' species and habitats (for which there is no accepted measure of what constitutes important). It is crucial that it is made clear that development will seek appropriate assessment of these non designated sites sufficient to ensure biodiversity is conserved and enhanced. The reference in the text to the Biodiversity Impact Calculator is wholly endorsed but it must be recognised that this tool is primarily intended to give an ecological value to non priority habitats. Application of the BIC to non designated sites will ensure that the post development ecological value equals or exceeds the original score, thus delivering the aims of NPPF. It must be made clear in the policy that it will be expected to be applied to all habitats of biodiversity value - not just those of important habitats or species. The phrase 'important habitats and species' will be too easily abused by unscrupulous applicants and their ecologists. It will be argued that only priority habitats and species are 'important' and therefore no other habitat will be taken into consideration. This is how ecological policies routinely fail at present and it is not what is intended in NPPF.

The supporting text referencing the calculator is in place but it needs to be triggered by a better worded policy addition. Therefore the following phrase should be changed from:

'Development proposals on non-designated sites that include important habitats and species will be expected to meet parts (b) to (d) of this policy.'

to:

'Development proposals on non-designated sites of ecological value will be expected to achieve no net loss and where possible net gains in biodiversity.'