MM 050 / FM 069

In regards to the latest modifications of the NHDC Local Plan; we would like to advise that overall we are in support of the modifications with regard to biodiversity. and very pleased that amendments have been made, These amendments include the addition to SP12 a x and NEx 11 xx of non-designated sites that include important habitats and species,

There are numerous sites within Hertfordshire that are very important in regards to habitat/species which have not been formally designated.

However, there is one point of the policy with which we wish to raise as a concern: 11.xx Sites allocated in this Plan have the potential to impact on designated biodiversity sites are required to provide an ecological survey and provide mitigation and/or off-setting measures as necessary. We would ask that it is amended to read ‘sites allocated in this plan that have the potential to impact on biodiversity are required to provide an ecological survey’ – the words ‘designated and sites’ should surely be removed as firstly there are many important biodiversity habitats that have not been designated and secondly, surely a site that has been designated as a biodiversity site shouldn’t actually be developed?

Although we are in support of the biodiversity modifications for this local plan - we need to reiterate that this does not include GA2 in which as you are aware, we have fully objected to HMNG advised earlier this year that to go ahead would be in breach of the law as it would be contravening the Badger Act 1992. We stand by our previous submission in requesting that GA2 is removed from the Local Plan as the situation regarding the protected species has increased since previous submissions and feel that a meeting on the GA2 site would give us the opportunity to be able to highlight the seriousness of the situation to the Planning Department.

In accordance with the modifications to Policy Nex - ‘Planning permission will only be granted for development proposals that appropriately protect, enhance and manage biodiversity’ which cannot be adhered to in this respect; it then goes on to state all development should deliver measurable net gains for biodiversity - again, this would not be the case in regards to GA2, it would in fact have a detrimental impact on biodiversity including the protected species. We, therefore, request that this site is reconsidered so that it can be withdrawn from the local plan saving any further action needing to be taken.

HMBG have worked with a number of LPA’s within Hertfordshire and we would like to be able to work with NHDC, in regards to the current local plan as well as future sites/plans, preferably at the Regulation 18 stage in the future.

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