Herts and Middx Wildlife Trust has the following comments to make on the main modifications consultation.

'Policy NEx Biodiversity and Geological Sites

11.xx Ecological surveys will be expected to involve an objective assessment of ecological value. Surveys should be consistent with BS42020 Biodiversity- Code of Practice for Planning and Development, or as superseded, and use the Biodiversity Impact Calculatorx , or as superseded, to assess ecological value. This methodology will ensure that appropriate mitigation or compensation is provided to meet the aims of national policy and is commensurate to the scale and location of the development and the likely impact on biodiversity, the legal protection or other status of the site.

Footnote x
x The Biodiversity Impact Calculator is a tool used to quantify the value of biodiversity at any site and can form an evidence base on required mitigation for a development, the amount of residual biodiversity impact, and if necessary, the amount of require offsite compensation. The current Biodiversity Impact Calculator is available on the Environment Bank website at : http://www.environmentbank.com/impactcalculator.php'

HMWT strongly support the use of the calculator but there are 2 issues with this section. The Biodiversity Impact Calculator referred to has been superseded by another since the this policy was written. The most recent update is the Biodiversity Impact Assessment Metric v19 produced by Warwickshire County Council and based on the DEFRA metric (as the BIC is). With this in mind the text should be adapted to read

'11.xx Ecological surveys will be expected to involve an objective assessment of ecological value. Surveys should be consistent with BS42020 Biodiversity- Code of Practice for Planning and Development, or as superseded, and use the Biodiversity Impact Assessment Calculator (Warwickshire County Council v19)x , or as superseded, to assess ecological value. This methodology will ensure that appropriate mitigation or compensation is provided to meet the aims of national policy and is commensurate to the scale and location of the development and the likely impact on biodiversity, the legal protection or other status of the site.'

Alternatively and given that the DEFRA metric upon which both of these calculators are based is in the final stages of review it might be better to replace this wording with more flexible generic wording i.e.:

'11.xx Ecological surveys will be expected to involve an objective assessment of ecological value. Surveys should be consistent with BS42020 Biodiversity- Code of Practice for Planning and Development, or as superseded, and use the NHDC endorsed Biodiversity Impact Assessment Calculator (based on the DEFRA metric) to assess ecological value. This methodology will ensure that appropriate mitigation or compensation is provided to meet the aims of national policy and is commensurate to the scale and location of the development and the likely impact on biodiversity, the legal protection or other status of the site.'

The wording of the footnote should then be adapted to reflect this:

Footnote x
x The Biodiversity Impact Assessment Calculator is derived from the DEFRA metric and is a tool used to quantify the value of biodiversity at any site. It can form a measurable evidence base on required mitigation for a development, the amount of residual biodiversity impact, and if necessary, the amount of offsite compensation required. The current approved Biodiversity Impact Assessment Calculator is available from the Local Planning Authority on request.

This is a much more robust and future proof way of ensuring the appropriate and most up to date metric is used. I have attached a copy of the latest version with guidance notes which can be distributed to developers and their ecological consultants - until the next update has superseded it.

The other issue with the current wording - which references a web link to the BIC - is that this link does not take you to the real Biodiversity Impact Calculator but merely a massively simplified proxy version which is actually not helpful. If the footnote is adapted to reflect the comments above it will ensure that the correct and standard calculator is used and avoid confusion and inconsistency.