Policy NHE2

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Comment

Wymondley Parish Neighbourhood Plan 2015 - 2031

Representation ID: 6444

Received: 28/07/2017

Respondent: Herts & Middlesex Wildlife Trust

Representation:

In order to provide more evidence to justify the use of the DEFRA Biodiversity Impact Calculator as a suitable mechanism to determine no net loss and net gain, I have attached the document: Environment Bank Planning Toolkit March 2017. This contains information on; justification for the use of the metric, how the metric was created by NE and DEFRA, how it has been upheld as a suitable mechanism to determine ecological impacts by the planning inspectorate and examples of its adoption in local plans and neighbourhood plans as the mechanism to determine no net loss.

Full text:

In order to provide more evidence to justify the use of the DEFRA Biodiversity Impact Calculator as a suitable mechanism to determine no net loss and net gain, I have attached the document: Environment Bank Planning Toolkit March 2017. This contains information on; justification for the use of the metric, how the metric was created by NE and DEFRA, how it has been upheld as a suitable mechanism to determine ecological impacts by the planning inspectorate and examples of its adoption in local plans and neighbourhood plans as the mechanism to determine no net loss.

Support

Wymondley Parish Neighbourhood Plan 2015 - 2031

Representation ID: 6450

Received: 03/08/2017

Respondent: Environment Bank

Representation:

We support the tone and theme of biodiversity enhancement and net gain running throughout the draft.

We welcome the reference to the DEFRA Biodiversity Impact Calculator and need for compensation as a last resort.

We would suggest an amendment in which the mitigation hierarchy is directly referenced.

Full text:

The tone and theme of biodiversity and net gain running throughout the draft Neighbourhood Plan is welcome, we particularly support the following:

"6.10 We expect that the planning system should contribute to the conservation and
enhancement of these ecological assets and to the ecological systems that support them. In accordance with the NPPF, development policies will seek to maximise the benefits of planning decisions to biodiversity, within the context of sustainable development.

6.11 In order to accurately determine whether no net loss and enhancement to biodiversity can be delivered by development, we expect that, when requested, precise ecological assessment
by suitably qualified people to accepted national standards be undertaken, sufficient to determine net gain.

6.12 The DEFRA and NE endorsed Biodiversity Impact Calculator (Environment Bank 2015 or as amended) has been designed to determine and quantify existing biodiversity value, in terms of habitats, and the consequent measures required to ensure no net loss and where possible net
gain.

6.13 When determining planning applications where there is a requirement to conserve and enhance biodiversity the following principles will be applied.

6.14 If significant harm resulting from a development cannot be avoided (by locating on an alternative site with less harmful impacts), adequately mitigated, or, as a last resort, compensated for, then planning permission will be refused.

6.15 Planning permission will be refused for development resulting in the loss or deterioration of irreplaceable habitats such as; ancient woodland, traditional orchards, aged, veteran, champion trees, or trees of a high conservation value located outside ancient woodland, unless the need for and benefits of the development in that location clearly outweigh the loss. In this instance substantial compensation consistent with the Biodiversity Impact Calculator will be
required."

We endorse the aims of this policy and support its retention in the final neighbourhood plan as it adheres to and strengthens national approaches set out in the NERC Act 2006, National Planning Policy Framework 2012, Natural Environment White Paper 2011, Planning Practice Guidance online and the British Standard for biodiversity in planning.

However, we would suggest an amendment in the form of a reference to the mitigation hierarchy where possible. The mitigation hierarchy is outlined in the NPPF (para 118) and is a key principal in environmental planning; it is important that the steps prior to enhancement are considered. It is further explained in PPG and BS 42020:2013.

An example wording for this would be: 'As per the mitigation hierarchy, if significant harm resulting from a development cannot be adequately avoided, mitigated, or as a last resort compensated for on, or off-site, then development will not be permitted.

Some background on the Environment Bank and our work is provided below for information:

Environment Bank is a private company working to broker biodiversity compensation agreements for developers and landowners.

We act as impartial advisers to Local Planning Authorities and are experts in biodiversity impact assessment and No Net Loss (NNL) strategies. We have partnerships and support relationships with over 25 LPAs across 15 counties - providing advice on local policies, planning guidance and strategies, together with support in implementation and individual planning cases. We have seen biodiversity No Net Loss, Net Gain and offset policies be adopted in Neighbourhood and Local Plans across the country.

Working on individual developments on behalf of developers and planning authorities we calculate the biodiversity impacts and enhancements of development proposals using approved Government metrics, determining residual biodiversity losses, if any, and proposing offsite compensation solutions. Our ecological experts then match a developer's compensation requirement with sites put forward by landowners and conservationists who undertake biodiversity enhancements on their land to generate conservation credits available as compensation. Compensation schemes must be the right type of site, of the right size, in the right place, at the right time, for the right cost. Credits are sold in exchange for the creation or enhancement of habitats, generating biodiversity gain. Thereafter, legal and fiscal systems assure planning authorities that such biodiversity compensation measures have been arranged independently and delivery will be overseen and guaranteed in the long-term, providing net biodiversity gain across a district.

Comment

Wymondley Parish Neighbourhood Plan 2015 - 2031

Representation ID: 6458

Received: 31/07/2017

Respondent: Hertfordshire County Council - Natural, Historic & Built Environment Advisory Team

Representation:

Policy NHE2 is supported in principle; however the use of the Biodiversity Impact Calculator should not be a requirement for all development proposals. It should be only be applied when and where appropriate.

The first sentence of paragraph 6.15 is supported, however any relevant compensation does not necessarily need to be consistent with the Biodiversity Impact Calculator, as there are other methods and tools available. Suggested "In this instance suitable" is replaced with "appropriate compensation will be sought."

Full text:

See attached

Attachments:

Comment

Wymondley Parish Neighbourhood Plan 2015 - 2031

Representation ID: 6569

Received: 04/08/2017

Respondent: North Hertfordshire District Council

Representation:

Policy NE5: New and improved public open space and biodiversity in the Submission version of the Local Plan already states that planning permission will be granted for development proposals which contribute to net gains in biodiversity. These policies do not add anything to the emerging policy framework.

Full text:

See attached

Attachments: