Comment

Proposed Main Modifications

Representation ID: 6809

Received: 29/01/2019

Respondent: Herts and Middlesex Wildlife Trust

Representation Summary:

Reference to the Biodiversity Impact Calculator should be replaced with reference to - a locally approved Biodiversity Impact Assessment Calculator derived from the DEFRA metric. Supporting text and footnotes should be adjusted to reflect this change. This will ensure the policy is cognoscent of occasional upgrades to the calculator and metric from which it is derived and therefore future proof.

Full text:

HMWT are very supportive of the requirement to use the Biodiversity Impact Calculator to determine measurable net gain. However we feel that this requirement should be slightly amended to account for the evolving nature of the metric upon which this calculator is based i.e. the DEFRA metric. Rather than stipulate the BIC, a locally approved biodiversity impact assessment metric derived from the DEFRA metric should be stipulated. This will allow for periodic upgrades to the metric to be accounted for (in effect these happen very rarely but should be accounted for). To put this in perspective, since 2014 when it was produced there has been one upgrade from this calculator tool and another one is immanent - the new DEFRA metric is out to consultation at the moment. So HMWT propose the following alterations to the wording to ensure that this policy is future-proofed:

'11.xx Ecological surveys will be expected to involve an objective assessment of
ecological value. Surveys should be consistent with BS 42020 Biodiversity Code of Practice for Planning and Development, or as superseded, and use the locally approved Biodiversity Impact Assessment Calculator 1, as derived from the DEFRA metric, to assess ecological value. Net positive ecological unit scores will be required to demonstrate net gain.'

This will necessitate the slight change of the footnote for 1 like so;

'1 A locally approved Biodiversity Impact Assessment Calculator is a tool endorsed by the LPA and derived from the DEFRA biodiversity metric which is used to quantify the value of biodiversity before and after development. This enables the net impact of development to be quantified and informs the required avoidance, mitigation or compensation measures (either on or offsite) for a development to demonstrate net gain.'

The following phrase below it in the text can therefore be removed because it is no longer necessary (and it directs the reader to the wrong tool anyway) Remove -
'The current Biodiversity Impact Calculator is available on the Environment Bank website at : http://www.environmentbank.com/impact-calculator.php'

Other text that refers to the calculator will also have to be slightly amended to be consistent with these changes, i.e.:

'11.xx Where required to do so, development proposals will be expected to demonstrate net gain to biodiversity by using the locally approved Biodiversity Impact Assessment Calculator, derived from the DEFRA metric.'

At present the most up to date metric is the Warwickshire County Council Biodiversity Impact Assessment Calculator v19. This should be circulated to ecological consultants (available from their website) until the new DEFRA metric calculator is available. As the LPA is made aware of any subsequent updates to the DEFRA metric (HMWT is happy to provide this advice), these can then be circulated to ecologist acting for developers as required. This will result in a more flexible and resilient biodiversity policy going forward.